ML21183A074

NRC-2021-00058 - Resp 1 - Interim, Agency Records Subject to Request Are Enclosed - Part 4 of 4

ML21183A074
Person / Time
Issue date:	06/30/2021
From:	NRC/OCIO
To:
Shared Package
ML21183A079	List: ML21183A069 ML21183A070 ML21183A071 ML21183A073 ML21183A074 ML21183A075
References
FOIA, NRC-2021-000058
Download: ML21183A074 (117)

Text

Tammara. Seshagiri From:

Sent:

To:

Subjec-c:

Attachments:

FYI-Pickett, Douglas Monday, September 29, 2014 7:56 AM Beasley, Benjamin; Burritt, Arthur; Tammara, Seshagiri; Mccoppin, Michael Paul Blanch letter on Spectra Energy Pipeline Paul Blanch letter 20140927 DEIS comments of Gas line.pdf Paul Blanch letter to FERC attached. Note that he copied the letter to Chairman Macfarlane - thu~ wP. may get a green ticket.

Paul M. Blanch Energy Consultant September 27, 2014 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room lA Washington DC 20426

Subject:

Algonquin Gas Transmission, LLC Docket No. CP14-96-000 FERC/EIS-0254D Dear Ms. Bose I am submitting the following comments on behalf of myself on the above-proposed project. I am a registered Professional Engineer with more than 45 years ofNucJear safety, engineering operation and Federal regulatory requirements.

I have been a consultant to the Chief Nuclear Officers at Indian Point and also an expert witness for the Attorney General for the State of New York related to the relicensing efforts oflndian point.

In October 2010 1 I petitioned2 the Nuclear Regulatory Commission (NRC) to evaluate the risks associated with the existing gas Jines. The NRC in its response stated this analysis had been conducted however they would not share it with me due to national security concerns.

I have conducted a detailed review of the Draft Environmental Impact Statement (DEIS) and the requirements as stated in 49 CPR 192

Transportation of natural and other gas by pipeline: Minimum federal safety standards" and also 30 CFR Part 380, Appendix A to Part 380 -

'Minimum Filing Requirements for Envirqnmental Reports Under the Natural Gas Act.

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September 27, 2014 Based upon these Federal requirements I have the following comments related to the DEIS and the Spectra application:

1. 30 CFR 380 (m)1 Reliability and Safety explicitly states:

"Describe how the project facilities would b,e designed, constructed, operated, and maintained to minimize potential hazard ro the public from the failure of project components as a result of accidents or natural catastrophes. (§ 380. 12(m)). "

This proposed line is located in the vicinity of residents, schools, churches and one of the largest nuclear plants in the USA. 49 CFR 192 discusses various design requirements for safety. I note that the new lines are not designed to the most stringent safety requirements of Class 4 lines. Contrary to these requiremtmts I did not see any discussion within the DEIS or the application discussing what provisions would be incorporated to minimize the impact to the public and why these lines are not designed to the maximum safety standards specified by 49 CFR 192.111 and 49 CFR 192.5. These standards would require closer isolation valve spacing, and mo1e robust pipes designed to withstand higher pressures. While not a specific requirement to design these lines as Class 4, rit was never anticipated that gas transmission lines would be located near or on the property of a nuclear power facility.

There is no dfacussion in either the AIM proposed description or the DEIS as to automatic isolation valves which had been remover from the originaJ gas lines. The only isolation valves are controlled from Houston, Texas and there is no assurance these will be operable due to an earthquake or other natural disaster.

2. The White Plains Journal News publis,hed the following Community View on September 15, 2014. Some of these may be new issues however none of thes~ issuies have been addressed in either the DEIS or the Spectra ApplicaLtion.

"View: Algonquin pla11, poses risks to 11.idian Poim, resident...

2 September 27, 2014 Paul Blanch 10 p.m. EDT September 14, 2014 Spectra plans to place a larger gas pipeline near Indian Point. The probability of a gas line failure is remote but is not zero. It is** unconscionable and irresponsible to continue this project prior to a comple.te, independent risk analysis.

Nuclear power plants and natural gas transmission lines provide energy for homes and businesses, Due to the inherent hazards associated with these energy sources, the federal government "regulates both. The proposed routing of the Algonquin natural gas pipeline near the Indian Point nuclear plant poses the risk that these hazards may team up to harm the community.

I speak as a professional engineer with more than 45 years of nuclear experience including formerly reporting directly io the Chief Nuclear Officer at Indian Point and an expert witness for the State of New York related to the relicensing of Indian Point.

There are three gas existing natural'gas transmission lines traversing the Indian Point site within600feet of vital structures. There has not been any publicly available analysis demonstrating the risks of these tines. The Nuclear Regulatory Commission has refused to provide this information under the guise of national s.wurity, yet has maintained the "secret" analysis shows Indian Point.is not at undue risk.

Failure of any o.f these Lines could result,in a &otal loss of cooling to the reactor cores and 40 years inventory of spent fuel. There are nu provisions within the area to combat this event until valves are remotely closed from the pipeline company's facility in Houston, Texas. In the meantime, the energy released.from a ruptured line in

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one hour would exceed the energy released.from one of the atomic bombs dropped on Japan in 1945.

Some of the possible consequences of a g,a,s line/ire/explosion to Indian Point include loss of power to the entire site, secondary jlres from liquid fuel storage tanks, reactor co.re damage and melting, asphyxiation of site personnel, spent fuel radioactivity releases exceeding th0se of Fukushima, and socia,lleconomic damages exceeding $/ trillion.

Now Algonquin/Spectra wants to place yet another high-pressure 42-inch line also in the vicinity of Indian Poi:nl, doubling the existing 3

September 27, 2014 capacity. According to the Federal Energy Regulatory Commission, "the proposed route would not pose any new hazard to the ( Indian Point) facility.

11 There is no way FERC could make this determination wirhout a complete risk analysis. An,d F ERC1s Draft Environmental Impact Statement ignores damage prevention, emergency response and public awareness, which are federal Department of Transportation requirements.

Al<?.01J(JUi1J..gq.u1ipeli.11e /!ll~iecJ_sparks sa/etv umcems An independent study of a gas pipelirze near a nuclear facility in anotlier state concluded it represented an undue risk. The amount of gas flow and energy in that pipeline was less than 1I1000 of the Algonquin/Spectra project and the facility was located in an area with much lower population.

The probability of a gas line failure is remote but is not zero especially if terrorism is considered; This may possibly be one of the most attractive targets in the nation.

The event would be aggravated by the decision of Spectra to not include any automatic gas termination valves and no means to combat the fire/explosion prior to gas flow termination. The gas lines are not designed to the most stringent safety standards as discussed in DOT regulations. The only gas isolation valves are remotely controlled from Houston, Texas. It seems the community around Indian Poiril is protected against a gas pipeline rupture triggering a nuclear plant accident-unless a gas pipeline ruptures. That's unacceptable.

The State of New York and all of the impacted counties must demand an independent and transparent analysis be conducted by an independent engineering organization. The cost for this study should be borne by Spectra/Entergy.

It is unconscionable and irresponsible to continue this project prior to a complete, independent risk analysis. The potential consequences of this event are too devastating to the New York area and my home State of Connecticut not to design this new line to maximum safety standards and assess the risk.

4 September 27, 2014 The writer, a West Hartford, Conn., resident, is an engineer "

3. 30 CFR Part 380 also requires:

( l) Describe measures proposed to protcd the public from failure of the proposed facilities (including coordination with local agencies).

(3) Discuss design and operational measures to avoid or reduce risk.

(5) Describe measures used to exclude the public from hazardous areas. Discuss measures used to minimize problems arising from malfunctions and accidents (with estimates of probability of occurrence) and identify standard procedures for protecting services and public safe1ty during maintenance and breakdowns.

Again, none of these requirements met or addressed.

4. Page ES-8 FBRC DElS states:

"Algonquin identified that because of the distance oftfle proposed Project from the IPEC generatingfacilities and the m1oidance and mitigation measures that ii would implement, the proposed route would 1101 pose am*

new s*afttJ'_)wzurds tn the IPEC /11cilir1*, To *msure that the A (M Project would not present new safety hazards to the IP EC facility, we are recommending that Algonquin file the Jinal conclusions regarding any potential safety-related conflicts with the IPEC based on rhe Hazards Analysis performed by Entergy."

This is one of the most egregious-state:ments within the DEIS and is an irresponsible and rash statement with no bases. The Nuclear Regulatory Commission (NRC) has re:viewed similar analysis at nuclear faci)jties nuclear facilities wjth l /1000 of the proposed gas flow and located more than one mile from the facility and determined that a 16*inch operating at 50-PSl. The study 5

September 27, 2014 performed by Framatome determined gas line presented undue risk to the faci lity. Any analysis conducted with a foregone outcome as stated within the DEIS is completely unscientific and irresponsible.

It should be FERC's responsibility to assure this analysis is conducted in an open, scientific, transparent independent manner with a peer review. This analysis cannot be conducted by any organization with a vested interest such as Sp ctra/ Algonquin, Indian Point/Entergy or the Nuclear Regulatory Commission.

West Point Pa11ners, LLC (WPP") proposes to construct and operate the West Point Transmission Project ("the Project") an approximately 80-mile-long high voltage electric transmission facility that will connect the existing National Grid Leeds I

Substation (Leeds Substation) in the Town of Athens, Greene County, NY, and the existing Consolidated Edison Company of New York Inc. (Con Edison), Buchanan North Substation (Bu hanan Substation) located adjacent t the Indian Point En rgy Center in the Village of Buchanan, Town of Cortlandt, Westchester County, NY. For approximately 77 miles of its length, the Project will be buried under the bed of the Hudson River.

Both the American Society of Civil Engineers3 and the National Association of Corrosion Engineers clearly state4 that high voltage direct current (HVDC) lines will induce stray currents" which will accelerate the corrosion of metallic piping systems. This HVDC line will directly intersect with both the new and 60 year old degrading existing gas tran mission lines and piping systems and tanks at the Indian Point facility.

49 CFR Part I 92, Appendix D to Part 192 - Criteria for Cathodic Prot ction and Determination ofMeasurements require this to be addressed and measures implemented to assure that there will be no jmpact or stray current corrosion induced by the HVDC lines in the proximity of the gas lines.

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5. 49 CFR J92.6155 requires "each operator shall establish wrinen procedures to minimize the hazard resulting from a gas pipeline emergency."

There is no discussion within the DEIS as to how this problem will be addressed especially when remotely operated valves are controlled from Houston, Texas.

6. 49 CPR §192.616 Public awareness requires "each pipeline operator must dev lop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see § 192. 7).

• There is no discussion within the DEIS of the application as to how this is being addressed. This public education process must include the potential consequences of impact to the Indian Point nuclear plants and how an accident would be minimized.

7. The requirements of 49 CFR 192 Subpart L----OPERA TIONS6 TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE: MINIMUM FEDERAL SAFETY STANDARDS are not addressed within the DEIS.

8. 30 CFR Part 380 states: Describe measures used to exclude the public from hazardous areas. Discuss measures used to minimize problems arising from malfunctions and accidents with estimates of probability of occurrence ( emphasis added) and identify standard procedures for protecting services and public safety dw*ing maintenance and breakdowns.'

There is no discussion within the DEIS as to how these requirements are addressed especially the probability and 5httr)/ww\\\\i,c *!'1:,g<>Ylc:12.i-bin/t.!\\l-idx'?Sl l2:_fet:d.1509ef9a6b.19ee 12 60_.1-2_.12281'c.l ~ nqpc:-: _g49.J. I Y-_ _I 615&rgn -d1v8 6!ll!:J)://w\\\\ w.ccfr. 11.ov/cgi-bi 11/t~xJ.:

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September 27, 2014 consequences of an accident and/or malfunction.

9. Based on the results of the Fukushima nuclear meltdowns the SociaJ and Economic consequences may exceed $1 Trillion should an accident occur with consequential damage due to proximity to Indian Point and NYC. Consequential damages from secondary fires and explosion from the millions of gallons of fuel oil stored on the Indian Point site must also be considered JO. The Nuclear Regulatory Commission has specifically notified7 all nuclear facilities of the potential dangers of locating gas Jines in the vicinity of nuclear plants. Neither the Spectra application nor the DEIS address this major risk.

There is no discussion of the potential for preventing terrorism and the impacts of such an event.

As stated in the DEIS: "To ensure that the A[M Project would not present new safety hazards to the IPEC facility, we are recommending that Algonquin file the final conclusions regarding any potential safety-related conflicts with the IPEC based on the Hazards Analysis performed by Entergy.

It is imperative that this "Hazards Analysis" be performed by an independent, qualified party with oversight from representatives from local legislators and residents.

In summary. the proposed AIM project poses extreme dangers to the residents of Westchester County and surrounding areas that include pipe corrosion to the new and existing gas lines, damage due to installation and subsequent construction accidents, and other events that may impact the environment.

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8 September 27, 2014 I would appreciate a detailed written response to these issues prior to the finalization of the DEIS.

Sincerely; Paul M. Blanch 135 Hyde Rd.

West Hartford, CT 06117 860-236-0326 Cc: Chafrman Allison M. Macfarlane USNRC Mr. John Sipos State of New York Assistant Attorney General 9

From:

Mccarver, Sammy Sent:

To:

Wednesday, September 24, 2014 8:36 AM Tammara, Seshagiri

Subject:

Attachments:

JPEC Responses to Your Questions for the Gas Line 50.59 Q ~stions and responses rev.docx Rao.

Attached doc contains latest responses from IPEC.

When do you anticipate completing your review? My bosses want to put our inspection feeder into the resident 3rd quarter report. Quarter ends Sept 30.

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SE@tJRJTV Rf!b'c:PEB litff0Rhb"tTtOH \\\\'f'.Fl It UOtO lJt48E:R l O CPR 1:.9'!18 Response to NRC Questions of 9/22/2014

1.

Provide the assumptions and inputs used for analysis methane mass, release duration, other inputs and assumptions for the Breeze and Alc>ha models).

Pv Pa The ALOHA model calculates release rates and dura1tions based on the size of the rupture, the pressure of gas in the pipeline before rupture and the length of pipeline upstream of the rupture. The size of rupture and pressure are presented in the report; details of the models used within ALOHA are presented In program documentation that are attached to this response.

In the Breeze Incident Analyst models for jet flames, the size of the flame and the resulting heat flux are determined by the initial gas pressure and size of the rupture. These data are provided in the report. It should be noted that the size of the jet flame will fall rapidly, particularly once the pipeline isolatfon valves are clos,ed, In the Breeze Incident Analyst models for a detonatio1n originating in the turbulent jet, the mass of methane gas involved is calculated for the ini1tial, maximum, release. This calculation is detailed in footnote 27 in the report. Th1us, for a double sided release of the 42" pipeline the calculation made is as follows, the constants being those referred to in the references cited:

14761.23 mm Hg Pipeline pressure 760 mm Hg Atmospheric pressure Actual dilameter of hole assuming guillotine On gamma 1.508966 1.31 m

rupture Do kl k2 Ma Ta To Mo Cl Cu 2.143448 9

12.7 28.97 298 298 16 0,05 0.15 Effectlve1 diameter of hole assuming gulllotine rupture Constant Constant K

Ambient temperature K

Pipeline temperature Molecul,ar weight methane Lower e,<plosive limit (fraction)

Upper e,(plosive limit (fraction)

Mass In jet 13211 kg 1

The determination of the mass of methane participating In a detonation occurring in the congested area comprising the belts of trees alongsidle the pipeline right of way is described in the response to question 5.

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CIIPITY Bil 1TliD~U+ORU1TIO~l B'ITHHObDllblL"liR IOCv'R47\\lQ In the.Jfeeze Incident Analyst models for dispersion made using the AFTOX model, the release r.;t~ assumed is based on ALOHA calculations allowing for valve closure after 3 minutes. ThI::; is described in footnote 23 in the report In all events involving the guillotine rupture of the pip:line, full bore release from both sides of the rupture is assumed-in practice the pipeline diameter is assumed to be 1.41 times its actual diameter.

2.

What assumptions regarding terrain of areas surrou1ndlng the pipeline were made?

Flat terrain is assumed. Given that methane Is a buoyant gas, it would be expect to rise and thus the terrain is of less concern than if the relea1se were to be of a dense gas.

3.

Can the calculations for Table 10 of the hazards anal*ysis be defined by source and methods? Original Question - The results summariz1~d in Table 10 using RG 1.91 methodology use the mass of methane provided in J~ppendix A(but not explained how these amounts are determined). Can these results be provided? Clarification - rn the Table on page A-2, third column, the mass of methaI1e (kg) for various types of releases are provided but how they are generated / calculated are not provided. Are the calculations for the determination of these amounts obtainable/ auditable?

The determination of the mass of methane involved in the hypothetical detonation of methane is described in the responses to questions 1 and 5. Essentially, for detonation in a turbulent jet, the mass is that of methane in the flammable range within the turbulent jet; for detonation in the wooded areas, the mass involved is assumed to comprise all methane In or above the flammable range in a belt of trees adjacent to the pipeline right of way.

4.

Is the Breeze Program public or proprietary?

Breeze Incident Analyst is a proprietary program that provides a user interface to a number of models and software developed by others. These liatter include models and software developed for and by US government agencies. Detc:1ils of the software can be found on the web site www.breeze-software.com/incidentana lvs1 S.

Did you use the same mass of methane In all the an.1lyses?

No.

The mass of methane involved in the hypothetical detonation within the turbulent jet is determined by the size of the rupture from which mett,ane was released (for a guillotlne rupture, this was taken as twice the pipeline cross-seGtional area to account for blow down from both sides of the rupture) and the gas pressure. While the flow rate of gas from the release will fall rapidly, the mass of flammable gas in the turbulent jet is assumed to be that prevailing initially.

For a hypothetical detonation within the congested aneas comprls,ng the belts of trees adjacent to the pipeline right of way, the mass of methane Involved in the explosion is assumed to be the mass of methane in or above the flammable range within the trees.

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• .~ is the area of gas in or above the flammable range shown by dispersion analyses that prevails a few minutes after the release starts when this area is greatest.

This area is determined by the rate of release, wind speed and direction..

6.

Were any other credits applied to the methane release due to the pipeline being underground?

3 No. It is assumed that any cover to the pipeline would be blown or scoured aside creating an open area around the rupture. It is also assumed that the methane jet created would rise vertically rather than impinge on the ground or the walls of any crater created. The latter would result in a loss of momentum and a reduction in the size of the turbulent jet or flame that ensues.

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• SECUl<I t i l<ELA I ED UQFORI IAIIOIQ Safety Review and Confirmatory Analysis of Entergy's 10 CFR 50.59 Safety Evaluation For Algonquin Incremental Market (AIM) Project at Indian Point Energy Center (IPEC)

Introduction

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Algonquin as Transm1s ion LL 1 1 1on9u1n proposes an Installation of new 42-inch diameter pipeline near the southern boundary of IPEC for the transport of natural gas as part of A IM Project, to replace the existing 26-lnch pipeline in vicinity of IPEC. which Will remain In place but idled. Entergy prepared a 10 CFR 50.59.(Rele~FIGe 1 J Safety Evaluation,Reference 1 related to the proposed AIM Proiect with an enclosure ot-' Hazards Analysis" (Reference 2l, covering consequen~s_of postulated fire and explosion following release of natural gas from the proposed new {southern route) AIM Project 42-inch pipeline south of IPEC and determination or exposure rates associated with failure of that proposed 42-lnch natural gas pipeline.

Based on the...a.iill:a6-hazard analyses and also accounting for the pipeline design and Installation enhancements, Entergy has concluded that the proposed AIM Project poses no increased risks lo IPEC and there Is no significant reduction in the margin of safety. Therefore. Entergy further concluded that the change in the design basis external hazards analysis associated with the proposed AIM Project does not require prior NRC approval.

The NRC Staff has reviewed Entergy's "Hazards Analysis" pMat t al *u

• 10 CFR 50.59 Safety Evaluation related to AIM Project, by performing independent confirmatory calculations to determine whether or not the licensee's conclusion Is reasonable and acceptable, and also to ascertain that there Is an adequate reasonable assurance for the safe operation of the plant or for the safe shutdown of the plan Technical Evaluation The ~

ndependent confirmatory analysts * !Q!.performed based on rupture of the proposed new 42-inch natural gas pipeline ~lnng *~e.01,11Rei:n l=GYl£i consisting of about 3 miles

• en,_olatton valves fof which the enhanced section of pipeline length ls ldentJfled 10 be 3935 ft c categ along U e southern route near IPEC The analys1 as um that ru tu of toe na!LJ[al ;as p 1.e1ine ma,--rewmng mfil!1i_in a.n unconfined explosion or jet flame at the source, & delayed vapor cloud fire. or vapor cloud explosion.

Missile generation may also accompany the ruptureJt; s,ooexp!os,on. For the assessn;:erJ' of an unconfined explosion. RG 1.91-(Reference 3) methodology *.!:@_Used to calculate !he minimum safe distance For the J ~ml flame,--aoo-cloud fire. and vapor cloud explosion. ttie_ALOHA I cllt1m1cal release modeling computer cod 1Reference 3) is used to determine the hazard impact distances which are compared with the aclual distances IP C

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'2-Z..2-3 f PRB will reconvene to reconsider its initial recommendation. If the PRB determines that the petition still meets the criteria for rejection, a closure letter will be issued to the petitioner, Mr Blanch.

Mr.Blanch accepted the second opportunity to address the PRB and he requested that it be held locally in the vicinity of the Indian Point site. He also sent a letter to Senators Schumer, Gillibrand, Congresswoman Lowey, and NY Assemblywoman Galef requesting their assistance in scheduling the next PRB meeting locally near Indian Point. Due to cost considerations and availability of staff to travel, PRB presentations have exclusively been held at NRC headquarters offices via toll-free telephone conference calls.

On May 14, 2015, members of the PRB briefed the Chairman on the 2.206 process and, in particular, how it was applied to the Paul Blanch 2.206 petition on Indian Point. The PRB informed the Chairman of the request by Blanch to hold the next PRB presentation locally in the vicinity of Indian Point and the Chairman deferred that decision to the staff.

The decision of the PRB is to hold the second presentation in Rockvtlle, MD. This is the practice of the staff and the staff is not aware of any PRB meetings being scheduled away from NRG headquarters. Concerns of holding a meeting at a local site would include crowd control and the ability of the PRB to accomplish its mission, availability of all PRB members to travel, and costs. Furthermore, holding the PRB presentation via telephone conference call will not inhibit the ability of the petitioner to communicate with the staff.

At approximately 3 p.m. on Monday, May 18, 2015, Mr. Blanch will be informed via email that the second PRB presentation will be held in Rockville, MD. He will be offered several dates and times in June for his presentation.

Audience and Stakeholders Int rnaJ Office of the Commission Office of the Executive Director for Operations Office of New Reactors (NRO}

Office of Nuclear Reactor Regulation(NRR)

Office of Nuclear Regulatory Research (RES)

Region I Office of Public Affairs (OPA)

Office of Congressional Affairs (OCA)

Advisory Committee on Reactor Safeguards (ACRS)

External Licensees Electrical Power Research Institute (EPRI)

Nuclear Energy Institute (NEI)

Congressional members State and Tribal governments public interest groups/non-governmental organizations Other government agencies media public Communication Timeline Date Summer 2013 February 28, 2014 August 6. 2014 August 21, 2014 October 15, 2014 January 2015 January 28, 2015 February 24, 2015 March 3, 2015 March 17, 2015 March 24, 2015 March 27, 2015 Mid-April 2015 April 27, 2015 April 28, 2015 Activity Spectra Energy approaches Entergy about proposed pipeline Algonquin Gas Transmission files application with FERC FERC releases draft EIS for public comment Entergy submitted their 50.59 site hazards analysis on docket Blanch submits his 2.206 petition Region I, NRR, and NRO staff discuss the proposed natural gas pipeline with staffers from NY state and Congressional offices.

Blanch makes presentation before the PRB The PRB makes its initial recommendation to reject the petition FERC approves the proposed pipeline Blanch submits an email to 1he Commissioners citing multiple deficiencies in the NRC's confirmatory analysis and requested that the NRC rescind its approval to FERG.

During testimony before the House, Appropriations Committee, the Chairman is asked questions regarding the staffs confirmatory analysis.

Blanch submits an email to the Chairman critical ot his testimony before the House Appropriations Committee on March 24. He also requests that NRC rescind its approval to FERC and that an independent study of the pipeline be performed.

NRR management approves the PRB's initial recommendation The PRB reconvenes and reconfirms its initial recommendation Blanch informed via email of the PRB initial recommendation

April 30, 2015 May 18, 2015 May 20 TBD TBD TBD Government-to-government meeting held in NY Blanch informed via email at approximately 3 p.m. that the second PRB presentation will be held in Rockville, MD, via telephone conference can. He will be offered multiple dates and times in June for his presentation.

Indian Point Annual Assessment Meeting Second presentation by Blanch before the PRB The PRB reconvenes to reconsider its initial recommendation If the PRB rejects the petition, a final closeout letter will be issued to the petitioner. If the PRB accepts the petition for review pursuant to 2.206. work will begin on the proposed Director's Decision.

Communication Team Name Telephone Number Email Contacts in NRR Benjamin Beasley 301-415-2062 Benjamin.Beasely@nrc.gov Mike Dudek 301-415-6500 Michael. Dudek@nrc.gov Douglas Pickett 301-415-1364 Douglas.Plckett@nrc.gov Contacts in Regional Offices Arthur Burritt (Indian Point 610-337-5069 Arthur. Burritt@nrc.gov DRP Branch Chief)

Diane Screnci (RI OPA) 610-337-8165 Diane.Screnci@nrc.go*v Neil Sheehan (RI OPA) 610-337-5331 Neil.Sheehan@nrc.gov Contact In OPA Scott Burnell 301-415-8204 Scott. Burnell@nrc.gov Contact in OCA Gene Dacus 301-415-1 697 Eugene.Dacus@nrc.gov Contact in EDO Cayetano "Tanny" Santos 301-415-7270 Cayetano.Santos@nrc.gov Questions and Answers

1. What Is the Algonquin Incremental Market Project (AIM)?

The AIM Project expands the pipeline capacity of Spectra Energy's existing Algonquin Gas Transmission system to allow regional natural gas supplies from the Appalachian basin through points Northeast including New York, Connecticut. Rhode Island, and Massachusetts. The new pipeline includes 19.6 miles of 42-inch diameter pipeline that Includes a new 1.2 mile horizontal directional drill crossing of the Hudson River near the Indian Point site,

2. What is the West Point Transmission Project?

The West Point Transmission Project is a proposed 1000 MW underwater power cable designed to bring power from northern and western New York State to the New York City area. The proposed route begins at the Leeds Substation in Athens, NY, and run approximately 80 miles below the Hudson River bottom before making landfall in Corlandt, NY. The cable will tie into existing transmission facilities at the Buchanan North Substation near the Indian Point site.

3. Why did Entergy perform a site hazards analysis?

Title 10 of the Code of Federal Regulations (10 CFR) 100.20(b) (Ref. 1) requires that the nature and proximity of hazards related to human activity (e.g., airports, dams, transportation routes, and military and chemical facilities) must be evaluated to establish site parameters for use in determining if a plant design can accommodate commonly occurring hazards, and if the risk of other hazards is very low.

In 10 CFR 50.34(a)( 1)

(Ref. 2), the NRC requires that an application for a construction permit include a description and safety assessment of the site on which the facility is to be located, with appropriate attention to features affecting facility design.

General Design Criterion 4, "Environmental and Dynamic Effects Design Bases," of Appendix A, "General Design Criteria for Nuclear Power Plants,* to 10 CFR Part 50,

Domestic Licensing of Production and Utilization Facilities," requires that nuclear power plant structures, systems, and components (SSCs) important to safety be appropriately protected against dynamic effects resulting from equipment failures and from events and conditions that may occur outside the nuclear power plant. These latter events include the effects of explosion of materials that may be at nearby facilities or carried on nearby transportation routes.

Regulatory Guide 1.91, "Evaluations of Explosions Postulated to Occur at Nearby Facilities and on Transportation Routes Near Nuclear Power Plants," describes methods for applicants and licensees of nuclear power reactors that the U.S. Nuclear Regulatory Commission (NRC) staff finds acceptable for evaluating postulated explosions at nearby facilities and transportation routes. It describes the calculation of minimum safe distance based on estimates of Trinitrotoluene (TNT)-equivalent mass of potentially explosive materials, the calculation of exposure rates based on potentially explosive carg,o transportation frequencies, and the calculation of blast load effects.

4. What Federal agency approves the proposed natural gas pipeline?

The Federal Energy Regulatory Commission (FERC) is the lead Federal agency. FERC prepared an environmental impact statement, held multiple public meetings, and issued a certificate approving the proposed pipeline on March 3, 2015.

5. What role did the NRC have with the EIS?

FERG sought NRC assistance to address the impact of the proposed gas pipeline on the Indian Point site. The NRC declined FERC's offer to be a "cooperating agency" in developing the EIS because the NRC did not have anything on the docket to base comments upon. Furthermore, had the NRC agreed to be a cooperating agency and hearings were held on the EIS, the NRC would need to support the litigation. Instead, the NRC agreed to review the draft EIS and provide comments.

6. What are the results of Entergy's site hazards analysis?

Entergy performed their site hazards analysis and concluded that coupled with the low probability of pipe failure, the new gas pipeline will not result in a more than minimal increase in consequences than that previously evaluated In the Updated Final Safety Analysis Report. Entergy performed this analysis pursuant to 10 CFR 50.59 whtch did not require prior NRC review and approval. Entergy voluntarily submitted their 50.59 evaluation on the docket for public availability

7. How does the NRC review 2.206 petitions?

The NRC reviews 2.206 petitions in accordance with the guidance of Management Directive (MD) 8.11. After a 2.206 petition is received, a Petition Review Board is set up.

The petitioner has an initial opportunity to address the PRB in order to provide additional or clarifying information. Following the initial presentation, the PRB meets to develop its initial recommendation to either accept the petition for review or reject it. Guidance to accept or reject the petition is included in the MD. If the PRB accepts the petition, work begins on the proposed Director's Decision. If the PRB rejects the petition, the petitioner is informed and offered a second opportunity to make a presentation before the PRB to provide additional or clarifying information. Following the second presentation before the PRB, the board reconsiders its initial recommendation. If the PRB still decides to reject the petition, a final closeout letter is issued to the petitioner.

8. Why are PRB presentations exclusively he!d at NRC headquarters offices via toll-free telephone conference calls as opposed to remote locations near reactor sites?

As a government agency, the NRC is responsible for considering the costs of conducting meetings and available options. The costs of travel for members of the PRB along with the costs of renting a suitable room for a public meeting will be significant. In addition, it is likely that not all members of the PRB would be able to travel to a remote site on a given date. Furthermore, the meeting location would not appear to offer any advantages in commurncaung concerns by the petitioners. As a result, PRB meetings have traditionally been held at NRC headquarters offices.

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• Pflll'l1SY'i!MtaBrwlCl'i Fltll Pr1:,t,,.cll(ri £ngr1((Eirg :n~ $f"(:1al Pr<,achi SOr.:11\\lO CHAPTER 15. ESTIMATING PRESSURE INCREASE AND EXPLOSIVE ENERGY RELEASE ASSOCIATED WITH EXPLOSIONS Version 1805.0 Parameters In YELLOW CELLS are Entered by the User.

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2338 'F He t of Cornbust1011 or tile Fuel {,\\H,)

Yield (u). 1,e, thu fraction of available combustion 1 percent for unconrined mass 1eloase and 100 percent for confined vapor release energy participating In bla t wave gon ration Mass of Flammable Vapor Release (mF)

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THERMAL PROPERTIES FOR FUELS FL/1.MMABILITY DATA FOR FUELS Fuel Adiabatic Flame Temp rature T..,(' F) 48380 kJ/kg 100.00 %

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,0.100 Ethane 44

,17 490 Ethylene 1 152 47 170 Hydrogen 4085 I30,~00 Methane 1143 1~0.030 n-Butane 2442 45,no n-Hoptane 2586 14 560 n-Pentane 2356 44.98()

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Date,__ ____ _, Organization!._ ____ _,

Date.__ _____ _. Organizationi.__ ____.,

Date JanuaN Luu4

PTN COL 2.2-1 Tur1<ey Point Units 6 & 7 COL Application Pari2-FSAR Table 2.2-213 Design Basis Events -

Explosions Heat of pounds 18, 6 poun s 19,782 8 u/lb (a) OuanUly of no1ural 9** relea5ad over, seconds "~"' a po,lUlared p1pallno rupture.

(b) Th& sirnultanoous dolonatlon of all Ille tubes conlalned In a 68,000 sci trailer s1ored 11 Units 1-6 ls not a plau,lblli SCiinario, lhersfclll, *n **pfo,lon Involving tho Wgest smgle tub 1, 1615 sef, was eveluatOd, 2.2-71 Revision 6

9 July 2015 Paul M. Blanch Energy Consultant Douglas V. Pickett, Senior Project Manager lndian Point Nuclear Generating Unit Nos. 2 & 3 USNRC Region l

SUBJECT:

Supplement to 10 CFR 2.206 Petition Regarding Violations of Regulations by Entergy Indian Point On October 16, 20 I 4, I submitted a 2.206 petition to request action against Entergy for providing Inaccurate and Incomplete information to the NRC alleging violations of 10 CFR 50.5 and 50.9.

On June 29 j 2015 j the NRC issued a letter addressed to me discussing the petition and the existing natural gas lines. This letter stated:

"Natural gas pipelines have existed on the Indian Point owner-controlled property since before plant construction. The Algonquin Gas Transmission Company built a 26-inch diameter natural gas pipeline in 1952 and an adjacent JO-inch natural gas pipeline in 1965.

Operating licenses were granted ta Indian Point Units I, 2, and 3 in /962. 1973, and 1975, respectively. The existing pipelines are located approximately 640 feet from the Unit 3 containment. The Atomic Energy Commission (AEC)/Nac performed confirmatory analysis to determine the impc1c1 of a rupture of the existing natural gas pipelines at the Indian Point facility in !97 3, 2003, and 2008. n Analysis by experts, the NRC/Entergy consistently calculate the probability of rupture of the new proposed 42-inch AIM pipeline to be in the range of 10-7 to I 0-4 failures per mile-year. Newly released NRC FOIA documents and references used to support the NRC and Entergy's risk assessment include information with the calculated damage radius from blasts, vapor cloud explosions, and jet fires, ranging from 845 to more than 8000 feet. This upper range would encompass the entire Indian Point site resulting in a total Station Blackout (SBO) with incalculable releases. The lower range from the existing gas lines would impact many safety related SSCs.

The existing 63-year-old line certainly has a much higher failure probability and is located much closer to vital structures. Its failure would have untold

consequences. The new documents also discuss the potential energy released, being many hundreds oftons 1 (TNT equivalent) prior to gas termination.

Entergy, in its most recent licensing bases in the FSAR clearly states that a failure of this 63-year-old line is not "feasible." While "feasible" is not clearly defined, to me it means a failure probability ranging from "impossible" to greater than 10*1.

Both ofthese statements provided to the NRC by Entergy, as part of its licensing bases cannot be accurate, Therefore, this is yet another example of Entergy providing inconsistent, inaccurate and erroneous statements to the NRC.

To further exacerbate this risk of the existing pipelines, we have been infonned that Entergy has no provisions or procedmes to identify and counter a failure of these existing pipelines.

Prrnl M. D111nch 135 Hyde Rd, We t Hartford. CT 06117 860-236-0:126 1 NRC email obtained under fOIA states 376,000 kg/mlm1tc would be released for lho first minute or ubuut 400 tons or ga~ pur minute or more than 4 kilotons TNT cqulivanl.

Toi.ALOHA model,or e)lplo conservatively

• _,.a...,,""'u......==-

e occurred at line above the surface. considering tt,e length of pipeline to ta maximum operating pressure oflni~p:-::sf.:,g:--..,;:-::-.,-,.;t:l"lf:-::::-=-,-~=:-:-r.:=::-i:=:"."!":"."."!=-::,-::-::re:-:s:-::u~lle::'.d~m a maximum sustained m,3thane release rate of256,000 pounds/mm, and estimated total release amount of 354,651 pounds averaged over 9 minutes, considering manua closure of the Isolation vallles within 3 minutes. ConservatiVely assuming 4

!!k,maxlmum release ver o minute

.i.256,000 pounds of mett,arieJ e TNT equfvalent amount __ 111 ~

yield fy!ctor of 0.05. the minimum safe distance

~,,Ge,i.;,:"'"'IE!fl lo 1 psi overpressure

• tc;yja~ t,. ~

2'351 It ll using RG 1.91 methodology as follows; WTNT= (Mf ~ OHC ' Y)/4500 d= 45 * (w) 113 where WTNT= TNT equivalent Mass, kg Mf

= Mass of vapor, kg DHC = Heat of combustion, kj/kg (50030)

Y

= Yield Factor (0.05) where d= minimum safe distance (ft) t.o 1 psi overpressure w= TNT equrvalent mass In pounds This calculated minimum safe distance of 2351_ ft is smaller than the actual distance of 2363.ft to SOCA from the pipeline at the far end above surface or 2988 ft to SSC (nearest SSC inside SOCA from this point is about 825 ft) and therefore 1 psi overpressure is not expected al any SSC inside SOCA

- potential rupture and explosion due te,eleaGe at the tar end of pipeline above surface. However, the SSC ITS would be Impacted. Nevertheless, their impacts are bounded by the severe/beyond design basis accidents consfdered as part of low probability events such as natural phenomena that include seismic, hurricane and tornado events covering Loss of Offslle Power and Station Black Cul (SBC) considerations with design of redundant systems, engineering safeguards and mitigation measures in the UFSAR The frequency of exposure due to failure of these SSC ITS from potential rupture or AIM Project is also briefly presented later In this report to address whether the margin of safety is reduced or compromised due to rupture or AIM Project.

Scenario2 Based on the assumption of 5% yield factor for unconfined methane explosion, the maxlmum 1 minute release of 256,000 pounds determined from ALOHA run is used as an instantaneous release in 1 minute. to simulate the vapor cloud dispersion, transport and delayed explosion( overly conservatiVely assuming congestion rn the area)with ALOHA model. The model determined minimum safe distance of3054fl to 1 psi overpressure due to delayed vapor cloud explosion which fs slightly over (65ft) the actual distance of 2988ft to SSC inside SOCA.

However, it should be noted that the determined minimum safe distance is based on overly conservative assumptions, and the actual distances are estimates presently due to undeveloped area, and the SSCs are generally designed lo withstand overpressure of 3 psi. This scenario is cons dered neither likely nor ctedible.

Methane is buoyant and quickly rises alo~ dispers*es rather rapidly. ALOHA model was rerun with the same Input except for opting no congestion in the area, ALOHA model resulted in no vapor cloud explosion of 1pst overpressure at any distance due to potential ignition.

Scenario l Comment [1111114)1 Clarify hew dotannlOOd/a,ssumed Tl'IT -equlY!I nt rrom na1lJral gas releaso rate D1d you auume that the Tl'IT-equllVldent weilili( wa tl'IG nme as the we,ght of the methaoe released?

1 Comment [mlll6]1 Wl1at dou 1h11 meal!')

The, e,cpc,nence presstJn!, but less lhan ~

Assuming 1 minute average release ot39406 pounds (354651/9) determined from ALOHA run, with TNT equivalent amount having yield factor of 0.05, the minimum sate distance of Jrblr7H* llj deteUilned to 1 psi overpressure using RG 1.91 methodology. This calculated minimum safe distance of ib)l7HF s smaller than the actual distance of 2383ft to SOCA from U'IO,' line at the far end above surface or 2988ft to SSC (nearest (b)(7'gjs~ 111,sl~~.. SQCA.from.thls point-is eboot,..

and therefore 1 psi overpressure is not expected at any SSC Inside SOCA, due to potential rupture and exp oslan due to release al the far end of pipeline above surface, Based on the assumption of 5% yield factor for unconfined methane explosion, the average 1 minvte release of 39406 pounds detemiined from ALOHA run Is used as an instantaneous release in 1 minute, to sirnulate the vapor cloud dispersion, transport and delayed explosion(overly conservatively assuming congestion In the (b)(7~

a) with ALOHA model. r,~.e rn?d~I ~:!~'!'1i!:'.~9.IJl]O.im.Umsafedistance.oE:::Jo 1 psi overpressure dUe to delayed vapor e1ouefex*p1os,on, and Is lower than the actual distance to SOCA of 2363ft, thereby posing no threat to SSC lnslde SOCA due to release from pipe rupture and potential explosion. Even though the average release assumption Is reasonable, assuming congestion in the area for potential explosion is overly conservative. ALOHA model was rerun with the same Input except for opllng no congestion n the area, ALOHA model resulted In no vapor cloud explosion of 1psl overpressure at any distance due to potential Ignition.

Scenario 4 ALOHA model was run conservatively assuming that the rupture of pipe occurred In the middle of the pipe located underground at enhanced section ldentified close to S'OCA. considering half the length (1.5 miles) on each side of pipe line, with rupture creating an hole equivalent to the diameter of the pipe at a maxirnum essure of 850 psig. ALOHA model run resulted i a maximu sus i e re e rate of !lli)[7)(F1 !

(b)(T)(Fl and estimated total release amount of (b)(1)(Fl considering closure of the isolatlon valves within 3 minutes. Since methane s re eased rom both ends of roken pipe, the total release rate is consldered to be the twice the above estimated amounts by ALOHA considering half segment of the pipe each side. Since the release is underground, and protective reinforced concrete mats are Installed above the buried pipirig, the rate of methane release to the environment is considered to be lower than the ALOHA determined maximum as well as average release rate, even though the total amount released eventually to the environment is same as that of the total release from the ruptured pipe at the far end above surface. The explosion Im acts are determined due to the unde round i e ru ture with the avera e release rate of methane and (b) 7 F b ) F based on 1 minute release and using the RG 1.91 methodology for explosion at source end using ALOHA for vapor cloud explosion as described earlier.

Assuming 1 minute average methane release of i(b)(7)(F)

!detemiined from ALOHA run, with total TNT e Uivalent amount accounting for two pipe segments, having yield factor of 0,05, the minimum safe distance of ibli711F is determined to 1 psi overpressure using RG 1.91 methodology. This calculated minimum safe distance o 1L117I(~ s smaller than the actual distance of 1580ft to SOCffle enhanced pipeline section or 1830ft to SSC (nearest SSC inside SOC'A frorn this point is abou lb)l7) nd therefore 1 psi overpressure Is not expected at any SSC inside SOCA, due to potential rup ure ancl explosion due to release at the enhanced pipelfne sectfon. Based on the assumption of 5% yield factor for unconfined methane ex loslon twice the amount of methane to account for two pipe segments the average 1 minute release of (h)(7)(r) etermlned from ALOHA run is used as an instantaneous release 1n 1 minute, to simulate the vapor c oud dispersion. transport and delayed explosion (overly conservatrvely assuming congestion in the 3 1401 c 31:0bfRFR Flfls eB 'ttC91iiMOtlQ:*

area with ALOHA model. The model determined minimum safe distance of (b)(7) o 1 sl ove ressure due to delayed vapor cloud expiosjonl and is higher than the actual distance to S o 1580 (b)(7)(F)

!(b)({)(f )

_ However, It should be noted that the determined m1nimu'-m* s-a""'fe_d..,.ls"'"t-an_ce_,,1s-~

based on overly conservative assumptions, and though the actual release is underground' and no credit is applied for expected slow release rate of methane. Therefore, a more realistic release scenario with a I.J 7 fiE'il"lflcredlt for slower release rate is assumed nd the minimum safe distance is determined by using (h)\\7) lttL_jof the methane release previously considered.

Assuming 1 minute average release of!(b)(7l(F)

!methane release rate detennined from ALOHA run as above, with total TNT equivalent amount for two pipe segments, having yield factor of 0.05, the minimum safe distance o (b)(7) s determined 10 1 psi overpressure using RG 1.91 methodology This calculated minimum distance of (F}

s smaller than the actual distance of 1580ft to SOCA rrom the enhanced pipeline section or 1830ft to SS nearest SSC Inside SOCA rrom this point rs about

!(ll)(7)(F) I and therefore 1 psi overpressure Is not expected at any SSC lmifde SOGA, due to potential rupture and explosion due to release at the enhanced prpellne section. Based on the assumption of 6% yield ractor for unconfined meth~D~ '":

losfoo tw:*=:e arnouot nf m:t:aio: t: ar:rnmt i:r two pipe segments the average 1 m1nute release of (b)(J{F !

hlethane release rate determined from ALOHA run s S as an 1119 an neous re(ease 11 m n fe,o s1mu ale the vapor cloud dispersion, transport and delayed e,i;ploslon (overly conservative! assuming congestion In the area with ALOHA model, The model determined minimum safe distance o lGH71 o 1 psi overpressure due to delayed vapor cloud explosion, and is smaller than the actual distance o A of 158 and to actuc1I distance to SSC inside SOCA of 1830ft Even though the assumption of the average release with (b}(7)(F) credit for slower release rate ot methane due to pipe rupture underground having pipeline enhancemen s,s reasonable, assuming congestion In the area for potential explosion is overly conservative. ALOHA model was rerun for both cases with the

,;::.::ll~=~ut~

that was used for the average methane release and also average methane release With 1L,)ll)(F)

(b)(7)(F) respectively as discussed above, e)(cepl for opting no congestion in the area In each case, ALOH model resulted in no vapor cloud explosion of 1psi overpressure at any distance due to potential Ignition for two cases modeled.

Methane ls buoyant and quickly rises aloft, disperses rather rapidly. The release of methane from a potential pipe rupture underground at middle of pipeline length of 3 miles (in enhanced pipeline section) and also a potential pipe rupture at far end of pipeline above surface are analyzed as discussed in scenarios above using RG 1.91 methodology and vapor cloud explosion using ALOHA model with overly conservative assumptions, as well as realistic assumptions. In spite of the analysis results based on reallstrc assumptions are used for the conclusion. the analysis with overly conservative assumptions though hypothetical and not credible are made to determine the variation of magnitude of Impacts. overall, based on the above analysis results (Table 1 ), II is concluded that 1 psi overpressure is not expected at any SSC inside SOCA. due to release of Methane and explosion from potential rupture of proposed AIM Project p1peflne near IPEC. However, the SSC ITS would be impacted, Nevertheless, their impacts are bounded by the severe/beyond design basis accidents considered as part of seismic and tornado events covering Stat on Black Out (S80) and Loss of Offs lie Power considerations with design of redundant systems, engineering safeguards and mitigation measures in the UFSAR. The potential explosions are not expected to generate fragments lo form damaging mlsslles.

JET FIRE

(ryps texl, Q&ll61iJiil f ieU, P PR f r;o If F9~M wlQ1i fT pe I X1)

ALmtA model was run conservatively assuming that the rupture of pipe occurred at far end of lhe pipe One above the surface. considering the length of pipeline to be 3 miles, wf h rupture creating an hole equivalent lo the diameter of the pipe at a ma><lmum operating pressure of 850 psfg Methane Is assumed to be releasing allJ.ll.!!,J,~.1.11.ta...111* &1..11~ Hammable burning gas ALOHA model run resulted in a mcl)(imum Bum rate of over duration of 9 minutes, consldenng closu~

allori val\\fes wIthIn 3 mtnutes (Table 2) lo the thermal radiation levels of~

5.0 kW/rr,2, and 2.0 Wo//m7 are respecthiely.

ALOHA model was also run conservatively assuming that the rupture of pipe occurred m the middle of the pipe located underground at enhanced sect on Identified close to SOCA, considenng half the length (1.5 miles) on each sfde of pipe line, with rupture creating an hole equivalent to the diameter of the pipe at a maximum operating pressu~ of 850 pslg. Me hane Is assumed to be releasing from ruptured Eii segments as a flammable burning gas. ALOHA model run resulted rn a maximum Bum rate of!(b)(7 F

~ver duration of 3 minutes, considering closure of tile Isolation valves within 3 minutes, The catcv1ated distances (Table 2) to lhe thermal radiation levels of!(b)(7)(F)

, 5.0 kWlm2, 2.0 Wt/Im~ are !(b)(7)(F) respeotlvely.

The distances determined to ltiermal radiation level of 12.5 kW/m (that has a potential to damage the structures and equipment) due to potential pipe rupture at far end of the p pellne or In middle of pipeline are

!tb)(7)(FJ lrespectlvely. Both of these determined distances are smaffer than the adual distances to SOCA of 2363ft and 1580ft respectively, and therefore. jet fire would not pose any adverse effect on SSCs related lo safety. However, it may impact some of the SSC ITS Nevertheless, their impacts are bounded by the severe/beyond design basis accidents considered as part of seismic and tomado events covering Station Black Out (SBO} and Loss of Offsite Power considerations With design of reduooanl systems, engineenng safeguards and mitigation measures in the UFSAR.

CLOUD FIRE ALOHA model was run conseNatively assuming that the rupture of pipe occurred at far end of the pipe line above the surface, considering the length of pipeflne to be 3 miles, with rupture creating an t,ole equivalent to the diameter of the pipe at a maxfmum operating pressure of 850 psig. ALOHA model run resulted in a maximum sustained release rate of 256,000 pounds/min, and estimated total release amount of 354,651 pounds ave raged over 9 mim1tes, considering closure ol the isolation valves withln 3 mrnutes The maximum 1 minute release of 256,000 pounds determined rrom ALOHA run ls used as an instantaneous release in 1 minute, to simulate the vapor cloud dlspersion, transport to determine distance to reach lower e.xplosive limit (LEL) of 44. 000 ppm. The ALOHA model determined a distance of 1.8 miles to reach the LEL This estimated distance would bound the potential distance to LEL rrom rupture in middle of pipe In enhanced area buried underground. Even though Methane plume travels to a long distance. since II is buoyant and quickly rises aloft, If enough oxygen ls avallable, it may bum rather rap\\dly In seconds much above the ground. Without sustaining.

Therefore, the impact from cloud fire on SSCs and equipment is not considered challenged.

DETERMINATION OF EXPO§URE RA.TE FOR FAILURE OF THE AIM PROJECT PIPELINE NEAR IPEC Based on Pipeline Hazardous Materials Safety Admin1Stration (PHMSA) data, and also published information from "Handbook of Chemical Hazards Analysis Procedures* (Reference 5), lhe accident rate of pipes greater than 20 inches diameter Is about 5 x 1 0"'/mite-yr Assuming 3 miles of AIM Projec! pipeline near IPEC, the accldent rat,e is determined to be 1.5 >< 10.;i/yr. Assumlng 1 percent of accidents result in complete break or 100 SfhS Or; Sf OF il f ELA,& IU Oki I HOf

percent release of which only 5 percent of time the rereased gas is either gets ignited leading to potential explosion, the frequency is calculated to be about 7.5 x 10-7/yr. If lhis release is due Lo underground pipe, the frequency of explosion wlll be further reduced by at least an order of magnitude. In addition, the frequency of la~e radioactivity release from the reactor due to the frequency above pipe rupture event would be at least few orders of magnitude lower, and therefore would not be identified as a design basis evenL Therefore, ii is concluded that the frequency of pipe failure resulting in a Methane release from proposed AIM Project near IPEC, would not reduce any further. the existing safety margins and would not pose a threat to lhe safe operation of the plant or safe hutdown RECOMME NOA Tl ON In order to Increase the margin of safety from potential impacts from the rupture of the proposed AIM Project pipeline near IPEC, Staff suggests following recommendations. It is to noted that these are just suggested recommendations but requirements.

1. Before initiation of constructfon of pfpeline near IPEC, relocate pipeline about 200ft farther away from SOCA. The safety related SSCs and SSC ITS would be farther from the proposed p,penne 2 Increase presently planned 100n wide clear buffer zone around buried p!J)E!lfne, 10 200ft wide clear zone, so that buoyant Methane disperses aloft wrlhout being trapped/accumulated, thereby reducing the potential for e)(ploslon.

CONCLUSION Based on the review of Hazards Analysis (Enclosure 2) prO\\/tded as part of Entergy's 10 CFR 50.59 Safety Evaluation related lo AIM Project near IPEC, and staffs independent confirmatory calculations and results.

assumptions and rationale. the staff concludes that the no 1 psi overpressure is extended to any safety related SSC Inside SOCA, l"IO thermal rad!atlon of~lJJ(/)(f) t,-ould be extended to any safety related SSC inside SOGA, Cloud flash fire may occur aloft and um very rapidly in few seconds, without affecting any safety related SSCs or equipment, and existing margin of safety is not expected to be reduced due to potential rupture of tt'le proposed AIM Project pipeline near IPEC. However neaJby SSC ITS would be affected but are bounded by the impacts from low probabifity events of extreme natural phenomena that include sersm1c, tornado winds, hurricanes which have been assessed and already addressed In UFSAR. The staff also concludes that the appllcant's conclusions that the potential rupture of proposed AIM Project pipeline near IPEC pose no threat to safe operation of the plant or safe shutdown of the plant. based on the Hazards Evaluation are reasonable and acceptable. and also comparable to slafl's conctusrons.

SCI -

IVE s_ect i £LJ5 _5.IC Oh !tt. OJC

eted REFERENCES

1.

Entergy, "1 O CFR 50.59 Safety Evaluation and Supporting Analyses Prepared in Response to the Algonquin Incremental Market Natural Gas Project Indian Point Nuclear Generating Units Nos. 2 &

3", eflGl8&1lF9 ~ 19 NL-1 4-106, August 21._2014. Ml 14245A 110

~

Entergy, "40-CJ:R ijO Ml Safel~ E*1al1mtl FHt~IAfj-Aflaly&es-fepar~-in Re&poose-kdhe AlgeF1qw1A IRGF&R'l&Fl\\al Uarket l'latural Gas PFejeGt IAd1an PeiRt NwGlear Geflerating-lmw;

_2. __ Nes. 2& aHazards Atialy 1s", Enclosure to 2-NL-14-106, August 21, 2014. ML14245A111 1NM rum!!.ru

3.

US Nuclear Regulatory Commission, Regulatory Guide 1.91, "Evaluations of Explosions Postulated to Occur at nearby Facilities and on Transportation Routes Near Nuclear Power Plants", Revision 2, April 2013.

4.

US EPA, NOAA.'ALOHA User's Manual", February 2007

5.

FEMA, US DOT, US EPA. "Handbook of Chemical Hazard Analysis Procedures" I

Formatted1 Numbered + Level; 1 +

Numbertng style: 1, 2, 3,.*. + Start at: l +

Alignment: Left + Aligned at. 0.25" + !Ment at: 0.75"

TABLE 1

SUMMARY

RESULTS OF EXPLOSION AND VAPOR CLOUD EXPLOSION Scenario Minimum Safe Minimum Safe Distance Distance Distance Distance Olstance(ft)

Distance- (ft)

(ft)

(ft)

(ft)

(ft)

Determined by toSOCA to SSC to SOCA to SSC Calculated by ALOHA from from from from From RG 1.91 Vapor Cloud Enhanced SOCA Farend SOCA Direct Explosion<*!

Pipelline from above from Explosion Enhanced Surface Far end above At Source Plf:!eline Pipeline Surface l(tJ)(7)(F)

(b)/7J 2

(b)(7) tJ NA 2363 2988 (I )

(F)

3.

)

NA 2363 2988

4.

1580 1830 NA NA

5.

1580 1850 NA NA (a) Wrth most conservative assumption of congestion and detonation of vapor cloud

e text TABLIE 2 ALOHA DETERMINED DISTANCE(FTl TO THERMAL RADIATION LEVEL DUE TO JET FLAME Pipe Rupture Location Pipe break at Far end of Pipe Above surface Pipe break in Middle in Enhanced Section Thermal Radlatlo~

2 kW/m2 5 kW/m2

~

(b)(!)(F)

New Jersey house explosion caught on da h cam (VIDEO) - AOL.com JJ;s~ he-u-s~ ~p!as-ien-saugMcH on *c1ash cam (VIDEO) l 1Gommens AP WAYNE PARRY Feb 25th 2015 3:13AM STAFFORD TO'MIISHIP, NJ. (AP). Fire Chier Jack Johnson was standing outside a home under renovatlon near the Jersey shore in the neighborhood where residents had reporled a strong smeU of natural gas Tuesday morning.

The rotten-egg smell of the substance added to odorless gas to wam people of a leak hung heavy In the air and was beginning to permeate the Stafford Township homes.

Johnson, fellow firefighlers. police officers and gas company workers were going house lo house, asl\\ing people to evacuate as a precaution while workers looked for the souroe of the leak.

The fire chief was about 50 feel from the unoccupied house. where workers suspected the gas was leaking, when a fireball burst Into the sky and a shock wave knocked several people on their backs and pounded their eardrums. Glass, wood and insulatlon rained down: strands of pink fiberglass hung from the pine trees 0ke wispy strands of cotton candy.

"It happened so quickly, the explosion, debris all around us coming from nowhere,* Johnson said. "II knocked you off your feel, a shock wave, the concussion of it. ti's something I never want to experience again.*

In that instanl

• captured on a police cruiser's dashboard camera

• 15 people were injured, two ol lhern critically.

Johnson was one or six firefighters and two emergency medical service technlclans to sustain concussion-like Injuries All but one had been treated and released from hospitals by Tuesday evening. Seven gas company workers also were injured, including iwo cri!Jcally who were within 20 feet of the house wtien it blew up.

Houses on either side were badty damaged, es was a parnally built one ac:ross the slree Stafford Police Capt.

Tom Dellan.e said other homes located within several blocks of the bias! also were damaged.

Page 3 of 19 http://www.aoJ.com/articie/20 15/02/25/new-ier ey-bouse-expJosion-caught-on-dash-cam-iniuries-report... 02/25/2015

New Jersey bouse explosion caught on dash cam (VIDEO - AOL.com vbn i11e1,s. oi 5taiiorti Township, saiti"i1e was oriving*iri iinrarea wi,en ne he'dn.i a iouu ex~o:iiun-ano ieii iile ground shake.

It was kind of hke a mini-earthquake,* he said. "You were thinking *1 was lil<e a bomb

• The cause of the 10:32 a.m. e*plosion has not been detennined. The blast occurred about an hour and a half after police received the first report of the strong gas smell. Emergency a-ews and gas company personnel responded and began evacuating 75 to 100 nearby homes.

About 300 homes remained without gas service Tuesday evening; some were also with01.1t electlidty. Michael Kinney, a spol\\esman for New Jersey Nature! Gas, said crows planned to WO(!( through the night lo make repairs and hoped to restore service by Wednesday morning.

Wayne Parry can be reached at hltpJ/twitter.corruWayneParryAC 0

SEARCH My Account Mall Join AOL Downloads Help &

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Pnvaey Terms About Our Ads Page 4 of 19 http://www.aol.com/article/2015/02/25/ncw-ierse -house-explosion-caught-on-dash-cam-ini uries-report...

02/25/2015

Tammara, Seshagiri From:

Sent:

To:

Cc:

Subject:

Attachments:

Importance:

NRO_FOIA Resource Monday, March 23, 2015 2:26 PM Mills, Vivian Crane, Samantha; Tammara, Seshagiri; Coates, Anissa; NRO_FOIA Resource FW: ACTION: SEARCH and REVIEW FOIA/PA-2015-00176 - All Writte.n Communications, both Internal and External to the NIK, To, Cc, and from Mr. Rao Tammara Related to the Indian Point Reactors. from 1/1/2014 through March 9, 2015.

2015~0176-r.pdt, How To Respond To An Initial FOIA(3).pdt, Final FOIA Cover Sheet Templates.doc; FINAL FOIA Memo.doc High ceed to the search and review o all records er rnent to his re ues ACTION: FOIA./PA 201!5-0176 - All Written Communications, both Internal and External to the NRC, To, Cc, and from Mr. Rao Tammara Related to the Indian Point Reactors, from 1/1/2014 through Morch 9, 2015.

J_

Due Date: Tuesday, March 31, 2015, NTL 3: 30pm For reporting purposes, the time expended on estimates. search, and review should be charged to TAC ZFOOOO Attach ents:

PDF of FOIA request How to Respond to an Initial FOIA Request Final FOIA Cover Sheet Final Memo Template

.N'RO :fOJ :A Team Yessie Correa - FOIA Coordinator - I E-mail: Yesste.Correa@nrc.gov I Office: (301) 415-6522 I Anissa Coates - Backup FOIA Coordinator - I E-mail: Anlssa.Coates@nrc.gov I Office: (301) 415*5812 I

Q.The Congresswoman questioned you on the use ofEPA's ALOHA program to calculate the safe distance from a postulated explosion of the proposed 42-inch gas transmission line.

Your response inferred that Regulatory Guide 1. 91 does not calculate the impact of a vapor cloud explosion, heat flux and/or jet fire. You indicated the staff would get back to the Congresswoman to clarify if required.

On March 24, 2015 Mr. Douglas Tifft provided the following clarification to your statement:

11 I did have the chance to check with our headquarters group that performed the analysis. ALOHA is used to calculate the amount of gas that would be released during a pipe break. That amount of gas is converted into pounds of TNT by our technical group. The pounds of TNT is used in the Reg Guide 1.91 formulas to determine the minimum safe distance. "

A. In determining the minimum safe distance to 1 psi overpressure using NRC Regulatory Guide 1.91 methodology, it is required to determine the amount gas available that has the potential for explosion instantly at the source from the release. This release rate could be determined by the equations available in standard literature reference material or using available computer models. In this case the ALOHA model calculated the maximum instantaneous release rate that is converted to TNT equivalent and used to calculate minimum safe distance to 1 psi following RG 1.91 methodology. The ALOHA model was not used calculate the minimum safe distance to 1 psi due to potential explosion of instantaneous gas release from the pipeline. Douglas Tift provided information includes this clarification. The Regulatory Guide 1.91 does not address and provide guidance to evaluate vapor cloud explosion, heat flux and flammable vapor concentrations from transport and dispersion of the gas released from the pipeline.

However, the ALOHA model calculates minimum safe distances to the 1 psi overpressure from potential vapor cloud explosion, limiting heat flux from jet fire, and flammable concentration limits for potential cloud fire based on gas plume transport and dispersion after the gas release.

Q. But page 146 of the ALOHA Manual specifically states:

"You can use ALOHA to model two types of gas pipeline leak March 27, 2015 scenarios:

• A pipeline connected to a very large (infinite) rese*rvoir, so that gas escapes from the broken end of the pipeline at a constant rate for an ihdefinlte period of time,* or

• A finite length of p.ipeline that is closed-off at the unbroken end (for example, by a shut-off valve). Because the pressure within this section of pipe declines as gas is released, release rate drops over time, and

the release continues only until the finite length of pipe is emptied.

ALOHA cannot model gas release from a pipe that has broken in the middle and is leaking from both broken ends." (Emphasis added by EPA)

A. The ALOHA user's manual addresses the ALOHA modeling capability of sources and scenarios and provides a sample input template on page 38 to be used for data input. The ALOHA model calculates the release rate of gas based on pipeline size, length, and its operating characteristics, and resulting potential impacts of vapor cloud transport and explosion, heat flux, and fire due to flammable concentration limits. For evaluating a pipe break in the middle, the NRC staff modified the ALOHA input data appropriately to represent the scenario being considered to capture conservative gas release rates to determine the amount of gas released in determining minimum safe distance to 1 psi overpressure using RG 1.91 methodology. The release rates determined by ALOHA are compared with average release rates calculated manually based on equations available in reference literature and reports. The ALOHA model calculated maximum and average release rates that are higher than that calculated by hand and, therefore, are considered conservative for this application.

Q,The NRC issued Revision 2 to Regulatory Guide 1.91 in April 2013. The purpose for this revision was stated as:

"Revision 1 of the guide did not address the effects of explosions from liquids, cryogenically liquefied hydrocarbons, and vapor clouds, (Emphasis added) or for fire and explosions from fixed facilities and pipelines. "

Regulatory Guide 1.91 Revision 2 contains 17 references, some of which may be used to calculate flow rates, vapor cloud explosions, jet fires and heat flux.

A. The NRC Regulatory Guide 1.91 revision 1, was issued in February 1978. This version based on information available at that time dealt with using conservatively total amount solid explosives, total weight of other potential explosive materials and mass equivalence of 240 percent for confined vapor clouds in determining minimum distance to 1 psi overpressure.

Therefore, the pipelines and fixed facilities might have been excluded due to lack of better estimation of amounts of material and their expected potential for less amount available due to unconfined explosion Due to recent approaches, new research and revised methodologies, Regulatory Guide 1.91 Revision 1 is revised to update to Revision 2. This revision expanded to include the sources that have been excluded previously and also to include TNT equivalent methodology for determining amounts of explosive material considering different yield factors depending on the chemical that is being considered for the evaluation. Nevertheless the basic evaluation of minimum safe distance calculation remain the same, though the actual amount of explosive material at the source or in vapor cloud using TNT equivalent methodology is updated. Therefore, RG 1.91 does not have provision

to calculate flow rates, vapor cloud explosion due to transport and dispersion, heat fluxes due to jet fires.

Q.lt is unclear why the NRC Staff used ALOHA when it is not cited as a reference and contains explicit prohibitions against analyzing this type of event.

A The ALOHA code is not used directly to determine minimum safe distance to 1 psi due to explosion instantaneously at the source, it is only used to determine the amount of gas available for potential explosion in calculating the minimum safe distance to 1 psi using RG 1.91 methodology.

which 1hey <:011,c 111 ordc.1* w <lo th*l'l r joh and 10 co11$itlcr how wu L'.Ul1 lcnrn t'nim lhl'. mu1rix LIi' \\!ill iii cs lliuI nrc <1111 th~r.:.

Pro(h1cing lhi~ Ialc11I llll!I I 1l1ink we Cllll do U hllllorjob nrli11k.igo~ t:iclWt.:C/l ihOSt! p};1cc~ lhnl IIIC Irni 11i11g wilh lhti-t' ll'hC*

1trc iJ0111g this mctudibly dlffir.a1l1 w<,rk :111(1 l would be there myself 1r yo11 co1nc. Thunk yI,1u, Can hcgm NCR hns ~0111ctliing Ln lenm nnd to npprct.:ia1c rro111 what is being dnnL' in places likl! I r,~prcsent. 13u1 J,ius1 wanIccl 10 poi111 out 1hc obscncc or 1hn1 whole rocu.s 011 workf'nrcc irnd rrnining in the ll'.~timony IIHII wns f>rCS<'llll!d Ioday. Th.ink you Mr. Ch;lirtnan J know there arc 011\\cr~ waiting.

SIMPSON: Ms. (inauc!ibh*l (UNKNOWN): Th,\\nk yew very much Mt*, Chairnrnn. I npologrzc for com111~ l,11e a~ th~ Clrnir ~now~ we haVL' sevcrul hearings al\\ schcclulcd l\\l 1hc s,\\mc litnu 1oday. So 1h~nk you for being here. My.:011gTcssio1rnl dimil't [11c:h1d<!,

Indian Point. which houses one dcco111111issio11erl, Mo nu,*l~ar power pl.mt~ arc ancl nper:itccl by Enteq~y.

Anmhc1 comp1111y Sp<!(;tra lw~ prupo~ltcl Ilic Al1wnqui11 l11.:rc111c11lal Murkct exp:in~ion which i~ c11lla<I lhc,,IM Prnjcct. which w(.)\\1lcl expand 1hc n111urnl g;\\s pipdi11c whid1 1rc111h vt-r,11~ the lntll~n l'oint properly This i~ a grc~t l:On~crn 11, me and 10 nwny nl my co11s1itu~11ts. m,tl I,trongl)* h..:licve that the NllC ha~ 1101 adcciumcly invcs1i11.iwu the risb mn rcspondcJ ~ub~111111ively 1111hr t'(illt'.c1n, 1h,11 lwvc [)c..:n ra,~e,J. Why did the NRC ri.:ly nn l~111crgy*~ h;in1rd.inolysi~ i11s1cud or purforming an i11dcpc11dcnt.mnl}*sis of ri~k and 1:t111,"qucnccs ni' conslrucl1on and op<:ral1011 or 1hc l\\lM project? That's lhc fi1*s1 qucs11ot1 BURNS: Well. 11c111ally, Cong.rt:~swonrnn tile NRC Jid review the energy analysis. /\\rid gi:t ii< owned confinm11ory an:1lysis c>f 1hl.! cncl'gy lrnzard ~nnlysis which they're required 10 ~uhmit to tis.

(UNKNOWN.): Out ii W1'sn'1 nn indcpcndcni mrnly~is of ri~k uncl r.on~equcnces of constructlo11 opc1111io11. w;,,

/

II.

BURNS; Well. ii,~ m1 ;1n11ly.~i~ lly our s111rr. We,tre incle['ll'11clcn1 or the upplicrint~ tlirough Ihc licensee. So fru111 that s1andpul111, I lhink Wtl' provided our Slnl'I did do 1111 nnnlysb 11l1tl dOClllllCllt<'d lilill n11aly~is 111 fin inspccllun n:ptll'L I think 1hc end of last yra1. Novc1111bcr last yc,lr.

(UNKNOWN}: I, thi*s typil::tl for our p1*11ct:tl11rt::'! We cJuu'I -* we rely nn the ow11d; 11m1lvsi~.

OUR NS: Wl'll, wt: cxpernn~ -- I rhI11k i1 is 1ypic~I 1ha1 we expect Ille licc11scc who h11s ultirnt11c responsibility. is responsible for snfr op~r:t1ion 011 th~.~ite. We Wtltlld expect lht:: liccn,l.!c 10 ~obmit the :'11\\uly~cs and 11l,;n W<' Wl*1Jid review tha1 ~nd rciu.:h our co11clus1L>11~ whetl1cr it w:1s conform,1tl 1n die 11n:1lytic11I,1and:mls 1hat 11r 111~ t1utco111c. l\\11d frurn my undemanding rhat's whcit 1hc swff Jid.

(UNKNOWN!: No\\~, rlirl th/: N RC cvnlualc tilt: impacl of drilling lluids used in the horizonml dirccllonal drill ing ror AIM 0111hc,pent fuel,od µools loca1ctl 111 lndia11 1'01111?

llUHNS: My under~tunding 1~ 1hni, 1hr horizon1:1l dircction11I drilling i~ pl:1nncd for 1h:11 ponion \\11'1hc pipeline 1h:11 runs unclcr lhc Hudson Riv<.'r, And the staff would ** d<)Cs 1w1 review or iri,pcct tww 1h:,t drilling would re performed p,mi\\:ulnrly in the river 1lm1 - in ihlll location is ubout a hall 1111 lc or ~o awn.i, from the.,ire,~ -- or t.hc spent fu.::I pool buildings a~ I 11tHlcrht1111d it.

The spcn1 fuel pool buildings nre scbmicnlly qunllllcil. scismicnJly designed n11u the it11p.ic1 of drilliug l'lu1d.,

wnuld 1101 h11ve nn 11npac1 as we: tt11tlcrs1a11() ii on those structures.

Umlcrg.rou11d dnlling with drilling lluids would h:1v.: lo b.: very clv~e Hild prox11niIy to Ihc,~pent lucl pnol ll11ild11\\g~ HI lhc pr(Jtcctcd !llt'!'I, 1'01 111~110 be or ;t ~llllll)' curn.:t:rn 10 lhC 11gcncy

(llNKNOWN): \\Veil. a:: I u11dorst~11/I it rm11fMll.'d 10 AIM 1hc1-: is u smal ler* p11>clillL' with ll*ll'l'r g:1. pl'c~~11r1.1 nc~r th(' T111'hcy 1'(1i111 1 u *!car Power Pinnt in Ho1111:s1c~cl Florida. I foll'l'vcr, the 'RC p1ccliclL'CI II ttr**lllt'I' !lilOla~,*

r,1d1us in 1=1oml11.Sc11111c* dirl rn AIM 111 Indian l\\1i111. Cun y1,u cxpl~11) why it doe~11*1 ma!;c illl) wn,c'!

lll)RNS: \\Vllll, 1111hc, T111*k *y f'uint ns I 1111\\IL,rst:inJ 11, in 1h~ Turkty l'llint 6 :111tl 7 1'11pli,*a11 111. 1h~ applir.,1111

,*v:llumc!I lhc 1111wrnl gns p1p.-linc n ar 1lw p111p11s1,:d 1111i1, Th ~ntt'I' c1*atu:11c I 1t1c pt11c:-,11i.1I d(c\\'t, i111h,* sn111c rn11111w1 1ha1 it dicl ** for 1hc AIM pnijcl'.t ~ind the rcsu\\ung effect.~ 1wrc lower Turk\\')' Po1111 clo 1hc smaller ~i7,\\.' of p1pcl111c Wh:11 lhc appli..:11111 ul Turkey J>oi11I did b iliat, 11 ~uh11111tcd :in an11l)'~*~ 1hnl u c ll vl.!ry cnl\\Sl',l'V!lliv 11,.,u111p111111 on. I 1hi11~, 1111 the cn11fi11cd L'Xplosion anti l'l\\SUlt in :1 laq,;l*r*..:;dcul111cd ch~11u1cc for 1m*,sum rclca~c (lr 11 I n:,,ul'l' w11vc 1h1111111,, NRC' arHlly. 1~.

Apui11, I think thal.11 1hc n11,* her\\\\ tl1c 11pplic~11t 1.k,1(11!' lo 11sc 11 \\11!1') rn11Ncr11n1h*c 11n:1ly~is We lhmrg.hl u~i11.c appmprlntu :inaly~c 1h:11 wa~ :1n*cp1:1hk ii' they w:111icd lo u~r a 11101<* n1n,crvl1(l anal) \\j~ ihcy l't,uld Bui ** in 11.:rn,~ n!'

1hc \\1llll'l>l11C, you knuw. we bclie,*c 1ha1 b111h the Turkey f>o1n1 si1ua11n11 uml the lnc\\1:111 Point s11ua1inn wn.: ~a11~lm:1nry.

(UNKNOWN): Well nrwlhcr qu~,;1inn. I dn11'1 undct'!;land wh, 1hc NRC the ALOI-LA 111:11111:.I 111~1cad of' the NJ{C Rl:'g11lu1ory Guitl~ I 91 whc11 ii pl:rf'ur111e.d,1 S\\!11, i1ivi1,v.~lll<I)'. and dct :n11in~tl that ;1 del:1ycd rln~ure ofrln* pipdi11r to iM1lmio11 valve urtcr u n1p111rc-. woul I result' i11 lll1ly ;1 n1inini.1I 111cr,*a~l' in 1wcrprc~~urc.iml hca1 flux HI sarc.1) rclnled i<tl'l1W1rc~ sy~1c111~ in co111pn11cn1h or lh\\! pln111'! Th<' ALOH t\\ 111otlcl 11,,11111\\*<I,111 i1Kidcnt.ii lhc t*11d~ uf the pipcli1w, lrh

• 1va * :1 rupture in U1c* midtll nf 1h.: pip.:linl' 1101 cnnsidcrcd'1 tnlRNS: OK, 1\\ gain fro111 Cl1 I 1111d rst.111Clin~ ill ~p<!aking Wtlh 1111,; NRC ~111rr th,11 till',\\ I.01 I,\\ 1l1C1Jei l nl~lll:ll,'1' the r,*k;1.~c r~tr () f g~s I 11sed on the pipeline,111(1 its t1pl'rn1i11!! chnr:i.:t,:ri<<li..:s. And cnmpi11c, 1lw rc~ ulli11!i... rk..:1, t\\f,1 v;1pw d ud cxplosil>nJ~t lir,: ht::it fh1.x, and r.:lo11d lir* bu~c(I 011 lln11111mblc ~011t:cnm11 i(111 limits, And end$ :111 in 1;111HmM11S cKpi\\1sio11. the 1\\ipc-ruµ111rc is 001 rnn~idcrcd r~11li.,1ic :111Ll 1101 i.:c1m p11 l *d by 1h~,1\\ I.Ol*IA rn,)1.h*I Thr calrulatcd release of g,as f'r11111 usi11i; 1hm model 11~1s use I to dc1~rn1111~ lh<' ;11rn1t1111 \\,I' gas 11v:11l:lhlc fm 1111 i11~111n1a11cwu~ cxplu.,io11. Now, lhc,*v,tlualicm nl' i11s1a11[a11cuus cxplo,i II u,,cd 111 lht'. r*egu\\J111r>* guidl' :1s nppnscll 10 lhl' ALOHA m1 dd. ll1 r1.1mp111r -* h~ l\\lny. h1lv1J u~cd 111 rnlllJlUIL' Ille TNT \\'tjl1i\\'nlc111 or.. lrn deti:rniin\\' 1i1L* mi,111num,:,t'i:

d1,1m1cc wl11':11: tht: m*.:rp11!ss11rc wou\\J be prcdic1cd I occur.

(UNKNOWN): We-IL Ihm\\ wtnu*~ pu1.1.li11g 10 111c-. l)~~n't Re.Jul thlt'Y Guide I IJ I l1:i1*c prcivi,~ion~ J~l 11illllt!.

r l 11rl fir..: anrl 1*111~11r i.:loucl?

UUR.': Nnw.,*~~c111ially. ag11i11. 111y u11dci'.-1a1Hling b 1h01 the Rceulnwry Guidi: I.\\JI t::lll'ulatc~ nli11irnurn.*uft 1fr;tanc11 by ov11lu,11ini; p(llcnliol *xplosi 11 ~, th~ ~n11r1.*(;'. based man.1moum 111' explosive in 1,*n1 s 111' *r 'T 1111J in terms 1if ** )OU hn,*~ 11 curti:lin :1111011111 nl'T~T at 1hu1 p. niculnr point,,md i1 me, 111..11c111p11rn1c for :i po1en1ial c,xplu.~1011 Th~r, re no1 p1'0\\iSiuns,,!'tt1c Reg.. Guide rnr rnp11r clnud c,xpln. 1011 or 1hi~ hem nux, orjt*I plan*, or vup111* loud (lJNKNOWN): Why i~ 1h111'!

BUl{NS: I 11n11Jd hill'C g.:t my s1al'f 10 c.~plain tlinl n111rc. \\g,tin, I 111in~ the ltlua i~ 1'1;1\\ R,~, nu1d,.. assume~ his.

1hc 1,*\\.111 n1ui vnlcni explo~1l'l11,~ 'rN1' wh:llrvc.r \\h~ ~oun:r ul' the c~pk1,~io11 is.

nu1 \\\\'C can ccnainly for 1h<! l'C1:nrcl prl)\\ idc you snm.: 1mm: i111'011Hatio11 or l1~vc 1lw,t,rr brief you. all,,r l c111r 1111'1' c111 th;il b~uc.

( LI NOWN): WL'II, 1h.111k yl111 fur your Cl\\111111~111,. 1\\~ )' 1)11 ca11.~l'l', I h:i(] m1111y p~l>pli: i11cl11cli11g uw~c-11 1h111 hnvc rn,il conct:rns.ibou1 thi: pruxi111i1y. A11d I hope we t'nn rollu1,up in th:11. tm au<li1k,n 11 in-depth dis,;u~"m1. 1ha11k

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(OFF-MIKE)

SUBJECT PETITIONER:

DATE:

10 CFR 2.206 PRB Closed Meeting Notes February 24~ 2015 BLANCH ET AL, 2.206 REQUEST! NG ENFORCEMENT ACTION AGAINST INPIAN POINT RE: NATURAL GAS Pf PELINES (OEDO-t4-00737)

(TAC Nos. MF5050 & MF5051)

Paul Blanch, assisted by Richard Kuprewicz October 15. 2014, supplemented by Accufacts letter dated November 3, 2014, Blanch letters dated November 11 1 2014 to Dori Willis and January 6, 2015 to Bill Dean, letters regarding ANSI Draft standard on Operator Action from the mid-1970s, and Petitioners' Presentations to the PRB during the Public Meeting on January 28, 2015 PRB MEMBERS & ADVISORS Ohris MIiler Lee Banic Doug Pickett Ben Beasley Mike McCoppin Rao Tammara Dave Beaulieu Paul Prescott Tom Setzer Greg Oberson Sergiu Basturescu Dori Willis Sean Mei han (lt)(aJ o

arpenter Dave Cylkowski (PRB Chair - Director, Division of License Renewal, NRR)

(Agency 2,206 Coordinator - NRR, Division of Policy and Rulemaklng)

(Petition Manager - Division of Operating Reactor Licensing)

(Branch Chle( Division of Operating Reactor Licensing)

(Branch Chief, Radiation Protection and Accident Consequences Branch, NRO)

(Radiation Protection and Accident Consequences Branch, NRO)

(SME for 1 O CFR 50.59, OPR/NRR))

(SME for Quality Control, NRO))

(Senior Project Engineer - Region 11 Branch 2. Division of Reactor Projects)

(SME for stray DC currents, RES)

(EEIB, NRR)

(Allegations Team Leader, DIRS/NRR)

(Allegations Specialist, DIRS/NRR)

(01)

(Enforcernent Specialist - Office of Enforcement)

(Office of General Counsel)

SUMMARY

OF REQUEST:

On October 15, 2014, Mr, Blanch submitted a 2.206 petition to the NRC concerning the 1 D CFR 50.59 site hazards analysis prepared by Entergy Nuclear Operations, Inc., the licensee for Indian Point Nuclear Generating Unit Nos. 2 & 3, The 50. 59 analysis was performed by the licensee to determine the safety impact on the Indian Point plant due to Spectra Energy's proposed 42-lnch diameter natural gas plpeline that is planned to traverse a portion of the owner controlled property at the Indian Point facility, In the petition, Mr. Blanch requested that the NRC take the following enforcement actions against Entergy, the licensee, for the following violations:

Violation of 10 CFR 50.9, "Completeness and Accuracy of Information." for providing inaccurate and incomplete information in the 50.59 site hazards analysis; Violation of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,* for relying on a contractor who was not qualified in accordance with Appendix B r:equirements; was not qualified in accordance with Entergy's Quality Assurance program; and, as a result, was not qualified to perform an analysis for such a significant safety-related issue; and Violation of 10 CFR 50.59, "Changes, Tests, and Experiments, for failing to perform the necessary safety evaluation requirements.

Furthermore, in the petition, Mr. Blanch requested that NRC issue a Demand for Information against Entergy for the following:

Demand an explanation from Entergy seeking an explanation as to why the previously identified violations do not also constitute a violation of 10 CFR 50.5, "Deliberate Misconduct;"

Demand that Entergy seek the results of a new and realistic risk/hazard analysis consistent with the guidance provided by OSHA Appendix C, Section 1910.119, "Compliance Guidelines and Recommendations for Process Safety Management;" and Demand that Entergy attest to the completeness and accuracy of Entergy report IP-PRT-08-00032 prepared in August 2008, that assessed the safety impact of the exis'ting 26 and 30-inch diameter natural gas pipelines that traverse the owner controlled property at Indian Point. That report was performed by the same contractor who performed the current site hazards analysis for Entergy. In addition, the report from August 2008 contributed to NRC's rejection of a previous 2.206 petition submitted by Mr. Blanch concerning the existing natural gas pipelines.

The petitioner supplemented the original petition with the following:

The Town of Cortlandt, NY, contracted with Accufacts Inc. to perform a review and analysis of the proposed Spectra Energy natural g;as pipeline and how it may affect Cortlandt. The Accufacts letter dated November 3, 2014, is critical of Entergy's 50.59 site hazards analysis and characterizes it as seriously deficient, inadequate, and under-representing the real risks. This letter supplements the Blanch petition.

The petitioner's letter to Dori Willis dated November 11, 2014, discusses the proposed West Point Partners construction of a high voltage direct current transmission cable that may run near, or adjacent to the proposed natural gas pipelines before tying into the Buchanan switchyard.. The petitioner has expressed concerns that stray DC currents emanating from the high voltage cable could adversely impact the existing gas pipelines, the new gas pipelines, and underground safety-related components at the Indian Point facility. This letter supplements the Blanch petition The petitioner's letter to Bill Dean dated January 6, 2015, asked why the isolation valves in the 42-inch natural gas pipelines would not be considered to be safety-relate.d as defined in 10 CFR 50.2, "Definitions. This letter supplements the Blanch petition.

The petitioner submitted three documents from the mid-1970s describing how the AEC/NRC developed the position for not allowing credit for operator actions in less than 1 O minutes following an accident. These documents, which include draft ANSI Standard N660, ~Proposed American National Standard Criteria for Safety-Related Operator Actions," along with comments from the AEC and the American Nuclear Society, supplement the petition.

The petitioner also supplemented the original petition with the following information provided during the petitioner's presentation before the PRB on January 28, 2015:

The petitioner, along with Mr. Richard Kuprewicz, questioned Entergy's assumption that the 42-inch isolation valves in the natural gas pipeline could be conservatively assumed to close within 3 minutes of a pipe rupture. The petitioner questioned the information available to the gasline operator based in Houston, TX, and stated that it would take significantly more time than 3 minutes to isolate the line.

The petitioner believes both Entergy and NRC under-estimate the impact of the heat flux generated by the fire. The heat flux is considered the limiting factor following a pipe rupture.

The petitioner requested that an independent analysis of a potential pipe rupture be conducted. The petitioner is willing to sign non-disclosure forms in order to review information currently being withheld due to security concerns.

BASIS FOR THE REQUEST:

As a basis for the request, the petitioner stated that the licensee's 50.59 site hazards analysis is incomplete and inaccurate. The petitioner has heavily relied upon the expertise of Richard Kuprewicz, President of Accufacts, Inc., who is highly critical of Entergy's site hazards analysis as well as the NRC's ability to appreciate the true risks associated with a large 42-inch gas pipeline. Both the petitioner and Mr. Kuprewicz call for an independent confirmatory analysis of a potential pipe rupture.

IS THERE A NEED FOR IMMEDIATE ACTION:

NO.

The Spectra Energy pipeline remains a proposal and it has not been built. As of this date, FERC has not granted a certificate for construction. In addition, the petitioners have not requested immediate action. Therefore, this is no need for immediate action.

DOES IT MEET CRITERIA FOR REVIEW?

Criteria for Reviewing Petitions Under 10 CFR 2.206:

1.

The petition contains a request for enforcement-related action such as issuing an order modifying, suspending, or revoking a license, issuing a notice of violation, with or without a proposed civil penalty.

YES. The petitioner has requested enforcement action against Entergy for violations of multiple regulations with regard to their 50.59 site hazards analysis.

2.

The facts that constitute the bases for taking the particular action are specified. The petitioner must provide some element of support beyond the bare essentials. The supporting facts must be credible and sufficient to warrant further inquiry.

YES. Both the petitioner and Mr. Kuprewicz stated that the Entergy analysis included multiple errors resulting in an inadequate analysis. Examples included use of an alleged non-qualified contractor to perform the Entergy blast analysis and the assumption that the pipeline isolation valves could be closed within 3 minutes.

3.

There is no NRC proceeding available in which the petitioner is or could be party and through which the petitioner's concerns could be addressed.

YES. Since formal NRC review and approval has not been requested nor required, there is no other proceeding available to the petitioner.

Criteria for Rejecting Petitions Under 10 CFR 2.206:

1.

The incoming correspondence does not ask for an enforcement-related action or fails to provide sufficient facts to support the petition, but simply alleges wrongdoing. violations of NRC regulations, or existence of safety concerns.

NO. The incoming petition requests enforcement action and provides sufficient facts to support the request.

2.

The petitioner raises issues that have already been the subject of NRC staff review and evaluation either on that facility, other similar facilities, or on a generic basis, for which a resolution has been achieved, the issues have been resolved. and the resolution is applicable to the facility in question.

YES.

The issues raised by the petitioner have been the subject of previous NRC staff review and the issues have been resolved as discussed by the following:

NRC Region 1 Integrated Inspection Report 05000247/2014004 and 05000286/2014004 dated November 7, 2014, describes the staff's review.

NRC inspectors and staff reviewed the 50.59 analysis and supporting hazards analysis report.

o Staff concludes that Entergy's conclusions that a potential pipe rupture poses no threat to safe operation or plant shutdown are reasonable and comparable to the staffs independent analysis.

NRC inspectors conducted a walk-down of the proposed pipeline routing to confirm assumptions used in the licensee's hazards analysis report.

NRC staff performed an independent confirmatory analysis of the potential hazards associated with failure of the proposed pipeline.

o The NRC analysis assumed rupture of the pipe results in unconfined explosion or jet flame at the source; delayed vapor cloud fire or vapor cloud explosion; and accompanying missile generation.

o The NRC analysis calculated minimum hazard distances for pressure wave and critical heat flux.

o The NRC analysis used conservative assumptions and rationale and concluded that safety-related SSCs inside the security owner controlled area (SOCA) would not be exposed to conditions exceeding the threshold for damage.

o Important to safety SSCs outside the SOCA would be adversely impacted. However, these impacts are bounded by low-probability natural events and have been previously assessed.

o Sensitivity studies concluded that an infinite source (i.e., the valves in the gas pipeline do not close) would not increase either the pressure pulse or heat flux to levels that would damage SSCs in the SOCA. Need to discuss 3 minute valve closure times.

o Concludes that both Indian Point units could safely shut down.

NRC inspectors reviewed the qualifications of Entergy's contractor who prepared their hazards analysis report to confirm that the contractor possessed the requisite knowledge, experience, and abilities to conduct the hazards analysis.

o In an allegation response to Mr. Blanch on the same subject dated December 19, 2014 (Rl-2014-A-0081). Region 1 made similar conclusions to the inspection report.

NRC inspectors reviewed the requir,ements of 10 CFR 50, Appendix B, UQuality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to confirm that Entergy's contractor was qualified within Entergy's QA program.

3.

The request is to deny a license application or amendment.

NO. The petition does not propose denying a license application or amendment 4

The request addresses deficiencies within existing NRC rules.

NO. The petition does not directly or indirectly address deficiencies within NRC regulations.

IS THERE A NEED FOR OE, 01, OIG, or OGC INVOLVEMENT*

YES. The petition requested violations (i.e., allegations of licensee wrongdoing) from 10 CFR 50.9, "Completeness and Accuracy of Information,"

10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,"

10 CFR 50.59, "Changes, Tests, and Experiments/ and possibly 10 CFR 50.5, "Deliberate Misconduct;

The PRB needs to decide whether 01 involvement is required and whether any issues should be pursued as allegations.

RECOMMENDED APPROACH AND SCHEDULE (Next Steps):

The initial recommendation of the PRB is to reject the petition on the basis that the issues have already been the subject of NRC staff review and resolution of the issues has been achieved.

The response to Mr. Blanch with our initial recommendation will state:

NRC inspectors have thoroughly reviewed Entergy's 50.59 site hazards analysis and conclude that the proposed pipeline does not represent an increased risk.

The NRC confirmatory blast analysis is conservative and supports Entergy's findings.

The NRC regional inspection thoroughly examined the qualifications of the Entergy contractor who performed the blast analysis and concluded that the contractor possessed the requis.ite knowledge, experience, and abilities to conduct the hazards analysis anp that Entergy's contractor was qualified within Entergy's QA program.

With regard to the assumption that the pipeline isolation valves will close within 3 minutes, sensitivities studies by the NRC assume an infinite source of gas which effectively assumes the pipeline valves do not close. The studies show that peak pressure and heat flux are only minimally impacted.

With regard to the statement that oil from the 200,000 gallon non-seismic diesel generator fuel oil storage tank (located adjacent to the Buchanan switchyard) will flow throughout the site and introduce large-scale fires that have not been analyzed, it will pointed out that local topography will prevent oil from flowing across the local access road, Broadway, towards the site. If the 200,000 gallon fuel oil tank ruptured, oil would flow away from the site.

With regard to the statement that stray DC currents from the proposed West Point Partners high voltage DC (HVDC) transmission cable (that will run along the bottom of the Hudson River before tying into the Buchan switchyard) will degrade the existing pipelines, the proposed pipelines, and existing SSCs at the site, it will be pointed out that the project has been suspended and that Entergy will need to consider any associated site hazards if the HVDC cable is built.

With regard to the request for an independent analysis, it will be denied based on the NRC's independent analysis. Conservatisms of the NRC analysis and the sensitivity analysis will be discussed.

All the other issues in the petition, identified and discussed in the attachedTable are rejected for the reasons discussed In the Table.

The next steps are:

Inform Jennifer Uhle of the PRB's decision.

If there are no concerns/objections with the PR B's initial recommendation, the petition manager wlll inform Mr. Blanch etal. of the PRB's initial recommendation.

Mr. Blanch et.al. will be offered a 2nd opportunity to address the PRB. If no new information is provided, the PRB initial recommendation will become final, and will be documented in a closeout letter.

Tammara, Seshagiti From:

Sent:

To:

Subjec:t:

Pickett, Douglas Wednesday, July 15, 2015 1:13 PM Miller, Chris; Beasley, Benjamin; Dudek, Michael; McCoppin, Michael; Tammara, Seshagiri; Cylkowski, David; Beaulieu, David; Carpenter, Robert; Wray, John; Thompson.

William; Solomon, Tahitih; Mensah, Tanya; Banic, Merrilee; Wilson, George FW: FW: [Fwd: Embargoed for Release - NRC Withheld and Misrepresented Critical Information Used to Evaluate and Approve the Siting of the Spectra AIM Pipeline Alongside Indian Point}

Please try to read this prior to today's PRB presentation

---

Original Message-----

From: Sheehan, Neil Sent: Wednesday, July 15, 2015 11 :44 AM To: Pickett, Douglas; Krohn. Paul; Lorson, Raymond

Subject:

FW: FW: [Fwd: Embargoed for Release - NRC Withheld and Misrepresented Critical Information Used to Evaluate and Approve the Siting of the Spectra AIM Pipeline Alongside Indian Point]

FYI

""**Embargoed for Release: July 15, 2015 at 2:30 p.m.*"'*

Contact:

Paul Blanch, pmblanch@comcast.net, 860-922-3119 Nuclear Regulatory Commission Withheld and Misrepresented Critical Information Used to Evaluate and Approve the Siting of the Spectra AIM Pipeline Alongside Indian Point On Wednesday, July 15, 2015 at 2:30 p.m. at the Hendrick Hudson Library in Montrose, NY, at a special presentation to the Nuclear Regulatory Commission's (NRC) Petition Review Board, nuclear expert Paul Blanch revealed that the Nuclear Regulatory Commission withheld and misrepresented critical information used to evaluate and approve the siting of the Spectra Algonquin Incremental Market Project's 42~inch diameter gas pipeline adjacent to the Indian Point nuclear power plant.

Therefore, the Certificate for the Spectra AIM project, issued by 1he Federal Energy Regulatory Commission (FERC) on March 3, 2015, which was based on the NRC's faulty am:1lysis. must be rescinded immediately.

Mr. Blanch began his presentation with this powerful statement:

"The NRC has threatened the safety of more than 20 million residents and the infrastructure of the greater NY metropolitan area and is risking trillions of dollars of damage and possibly the US economy by basing its safety assessment on a calculation that was recently obtained from the NRC under FOIA[1). This new Information confirms that this NRC 'calculation' which was partially handwritten, unapproved, undated and unsigned, used fictitious, false and unsupported assumptions. This NRC calculation supported the FERC approval of the AIM project and the transportation of thousands of tons of TNT equivalent across and in the vicinity of the Indian Point nuclear plants. This 'back of the envelope-type calculation,'

which misled Congressional representatives, FERC and the general public, must be invalidated and an independent, transparent, structured risk assessment, as outlined in an Occupational Safety & Health Administration l

(OSHA) methodology, must be unaertaken.

Nationally recognized pipeline expert Richard Kuprewicz, engaged by the Town of Cortlandt to analyze the project, provided formal comments to FERC in November and December. Mr. Kuorewicz oarticioated in the NRC Petition Review Board call. He stated:

In reviewing the various analyses of information provided to date, it has become obvious that those attempting to perform rupture dynamics of the 42-inch pipeline should not be doing such work, as their analyses consistently fail to capture the fundamental basics of gas pipeline rupture dynamics, especially on this system in the vicinity of the nuclear plant. From my perspective, ft appears the permitting agencies are attempting to take advantage of a loophole that permits the NRC to dismiss risks If such analysis can be categorized below a certain threshold value, while ignoring the severe consequences that might prevent the nuke plant to safely shutdown."

Mr. Blanch discovered the new information through a Freedom of Information Act (FOIA) request of NRC correspondence resulting from a letter to Assemblywoman Sandy Galef from the NRC. The links to the FOIA documents are available here:

Link to FOIA document #1 https://drive.google.com/file/d/0B9zj5jrshSGjNThTek5VczhuNTgyTEZwUIJaSHRkMkoyanZB/view?usp=sharin g

Unk to FOIA document #2 https://drive. google.com/file/d/0B9zj5jrshSGjTj BKUIE 1 Y2 MzQXEzX0RzcjJkdTV JeG9F aDh3/view?usp:::sharing Assemblywoman Galef, who hosted the press conference prior to the presentation said, "At the press conference I joined my colleagues and elected officials to hear more about the grave concerns with the siting of the Spectra AIM pipeline so close to the Indian Point Nuclear Power Plant.

We will continue to advocate for greater scrutiny and a halt to this project unless and until it can be determined that this is safe. Right now, we have no such assurances."

Background:

According to another FOIA of until-now-private NRC emails, a rupture of a gas pipeline of this pressure and diameter, would release about 4 kilotons of energy a minute. To put this in perspective, the nuclear blasts at Hiroshima and Nagasaki were about 15 kilotons[1). While this energy release wouldn't cause the same type of damage, it could cause continuous explosions, which could destroy systems required to shut down the Indian Point reactors, which could cause major release of radioactive material that could impact a 50 mile radius (like Fukushima). Yet. the NRC continues its claim of "no additional risk."

The risk analysis performed by Entergy and confirmed by the NRC states that if the pipeline ruptures, Spectra Energy's operators in Houston would be able to shut down the gas flow in 3 minutes. Most gas line ruptures require field verification, which takes additional time. When a pipeline in San Bruno, CA ruptured, It took hours to get it under control.

If the NRC had used accurate information concerning the dynamics of a pipeline rupture, the impact radius of the explosion and heat flux would have been dramatically expanded, This would have demonstrated that a rupture could lead to a total electrical failure including back-up systems regardless of whether they shut the valves in 3 minutes or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Had the NRC provided accurate Information to FERC and the involved agencies, the siting of the pipeline alongside Indian Point would most certainly not have been approved. While Fukushima was caused by an unforeseeable tragedy, putting the AIM pipeline next to Indian Point creates the potential for an avoidable

tragedy,

2.

Persons not able to attend the meeting may llsten by calling the conference bridge number at 888-469-1340 with passcode !(b)(6)

I A Q&A with Mr. Blanch and Mr. Ku rewicz will be held following the NRC call. Please hang up and redial this number; 605-562-3000 Code (b)(6)

[1) NRC FOIAs 2015-00176 and 0246 include an NRC internal email that discusses gas release rate of 376,000 kg per minute, which is nearly 1 million pounds per minut1~ of explosive gas. Natural gas contains 10 times the energy per pound than TNT.

About Paul M. Blanch 45 Years Nuclear Power Experience, Navy Submarine Reactor op,erator and instructor, BS Engineering 1972, Registered Professional Engineer, Westinghouse Engineer of the Year, Participated in design of Millstone and Connecticut nuclear plants, Three Mile Island exper1 witness, Davis Besse expert witness, Testified before US Senate, Vermont and Massachusetts legislatures Employed by/Consultant to:

Millstone Connecticut Yankee Maine Yankee Indian Point (Consolidated Edison and Entergy)

Electric Power Research Institute {EPRI)

Nuclear Entergy Institute (NEI)

State Agencies Numerous Law Firms Riverkeeper Expert Witness for License renewal (10 CFR 54)

Indian Point License Renewal Vermont Yankee License Renewal Pilgrim License Renewal Seabrook license Renewal Identified numerous shortcomings in the NRC's License Renewal Iprograms/reviews including Piping degradation Unqualified submerged vital cables Failure to require aging management programs for numernus 3

passive components Identified and petitioned the NRC to take action related to gas transmission lines at Indian Point About Richard Kuprewicz Mr. Kuprewicz has over 40 years experience in the energy industry offering special focus on appropriate pipeline design and operation in areas of unique population density or of an environmentally sensitive nature.

He is currently a member of the U.S. Department of Transportation Hazardous Liquids Pipeline Safety Standards Committee (THLPSSC) representing the public, a position appointed by the Secretary of the Department of Transportation. He has also served in the-past on the Washington State Citizens Committee on Pipeline Safety a committee appointed by the Governor of the state that advises federal, state, and local governments on all matters related to pipeline safety, including routing, construction, operation and maintenance. He is a chemtcal engineer, experienced in production, pipeline, and refinery design, construction, operation, maintenance, risk analysis, management, acquisition, emergency response, and safety management processes, including hazard analysis. He has also authored many papers on pipeline safety, both nationally and internationally, and has proved various inputs throughout the development of federal pipeline safety regulation including liquid and gas pipeline safety rulemaking.

Suzannah Glidden, co-founder Stop Algonquin Pipeline Expansion (SAPE) www.sape2016.org 914-485-1052 suzannahglidden@optonline.net 4

Tammara, Seshagiri From:

Sent:

To:

Subject:

McCoppin, Michael Thursday, July 16, 2015 1:12 PM Tammara, Seshagiri FW: REQUEST FOR BRIEFING ON INDIAN POINT GAS PIPELINE Rao... can you please pull this together for us?

From: Kock, Andrea Sent: Thursday, July 16, 201S 12:59 PM To: McCoppin, Michael

Subject:

REQUEST FOR BRIEFING ON INDIAN POINT GAS PIPELINE Mike: since our involvement in and questions regarding the technical analysis RPAC completed for the Indian Point gas pipeline continue, I'd like a briefing on the technical analysis Rao completed to support our conclusion that there is no safety impact. I'd also like the briefing to cover the issues raised in the rece t petition, our response to those issues, and the status of the PRB.

I'd prefer we meet in the next week, but if you can't make that happen with your anticipated schedule, early the following week (07/27) will do. Please invite Scott.

Thanks Andrea Kock, Deputy Director Division of Site Safety and Environmental Analysis Office of New Reactors United States Nuclear Regulatory Commission Ph. 301-415-2368

Tammara. Seshagiri From:

Sent:

To:

Subject:

For awareness..,

Original Message-From: Mccarver, Sammy McCoppin, Michael Friday, December 12, 2014 8:19 AM Tammara, Seshagiri FW: Draft responses to NRC QL1estions re: AIM Project - P1 ioilcgcd u;;d E0iiRdc11t,al Sent: Friday, December 12, 2014 8:09 AM To: Tifft, Doug; Lorson, Raymond; Burritt, Arthur; Krohn, Paul; McCoppin, Michael Cc: Dimitriadis, Anthony

Subject:

FW: Draft responses to NRC Questions re: AIM Project - Pri*.,ile~ed ens Sent.ae"tial Below Is the draft response I received from Entergy/lPEC regarding our questions on Spectra's monitoring of the gas line and the basis for the 3 min closure time Entergy/lPEC used in their 50.59 analysis Sam Mccarver From: Prussman, Stephen G [SPrussm@entergy.com]

Sent: Friday, December 12, 2014 4:24 AM To: Mccarver, Sammy Cc: Pickett, Douglas

Subject:

FW: Draft responses to NRC Questions re: AIM Project* Plioilcgcd e11d Oel"tFider.tial Mr. Carver, you recently asked for certain additional information related to Entergy's 10.C.F.R. 50.59 Safety Evaluation and supporting evaluations prepared in response to the proposed Algonquin Incremental Market Natural Gas Project {AIM Project), including the basis for certain assumptions in those analyses. We provide our responses below, As a preliminary matter and as NRC Is aware, Entergy Is not the sponsor or applicant for the AIM Project which Is pending before the Federal Energy Reglllatory Commission (FERC). Entergy's involvement is limited to evaluating any increased risks or consequences to Indian Point pursuant to its obligations as the licensed operator for Indian Point Units 2 and 3. As such, Entergy has worked closely with Algonquin to better understand the scope of the AIM project and confer regarding means to avoid any potential adverse impacts to IPEC. In doing so and as dlscLissed further below1 Entergy relied on certain information filed by Algonquin with FERC and on information provided by Algonquin to Entergy related to piping system operations.

Question 1: Can Entergy provide information regarding how Spectra maintains control (monitors) over the closure of the gas pipeline. How do they know that there is a rupture and how long will it take them to react and how long will it take the valves to close.

Resource Report 11, "Reliability and Safety," filed with FERC by Algonquin in February 2014 related to the AIM Project states as follows:

"A gas control center is maintained in Houston, Texas. The gas control center monitors system pressures, flows, and customer deliveries. Further, the gas control center is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 365 days a year, Algonquin also operates area and sub-area offices along the pipeline route whose personnel can provide the appropriate response to emergency situations and direct safety operations as necessary. Algonquin's proposed AIM Project pipeline will be equipped with remote control shutoff valves as required by the USDOT regulations. This allows the shutoff valves to be operated remotely by the gas control center in the event of an

emergency, usually evidenced by a sudden loss of pressure on the pipeline. Remotely closing the shutoff valve allows the section of pipeline to be isolated from the rest of the pipeline system. Data acquisition systems are present at all meter stations along the system. If system pressures fall outside a predetermined range, an alarm is activated and notice is transmitted to the Houston gas control center. The alarm provides notice that pressures at the station are not within an acceptable range."

In addition to the above information filed with FERC, Entergy conferred with Algonquin regarding remote monitoring of gas pipelines and responses to potential pipeline ruptures. Algonquin confirmed that the gas control center is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 365 days per year. Algonquin also stated that electronic instruments at the valve site provide an alarm signal to gas control center if abnormal flow conditions occur, e.g., a pipeline pressure drop. The well-trained gas control personnel can then immediately diagnose the situation. Gas control personnel will acknowledge an alarm in seconds and will initiate a 'close' command following prompt evaluation of data generating the alarm condition, and sending a "close* signal to the valve takes only seconds, and the valve closing time is a little over one minute. An Entergy consultant also independently determined that natural gas isolation valves, similar to those proposed to be used on the AIM Project near Indian Point, generally close at approximately 1 inch per second. Therefore, a 42-inch valve is expected to close within the one minute timeframe provided by Algonquin.

Question 2: Entergy used a three minute valve closure time in its evaluation of the AIM Project. Does Entergy have any more information as to why this time is appropriate?

As noted above, the estimated valve closing time for a 42-inch natural gas pipeline is approximately one minute. As documented on Sheets 7 and 8 of Entergy's 1 0 CFR 50.59 Safety Evaluation Form submitted to the NRC on August 21, 2014 (available on ADAMS as of September 12, 2014 at ML14253A339), Entergy also estimated the time for Gas Control Center personnel to respond to an abnormal flow condition alarm and Initiate a valve close command at one minute. Entergy then conservatively estimated a total of three minutes.,

in its evaluations of the AIM Project. Further, as documented on page 16 of the supporting AIM Project Hazards Analysis, Entergy did not assume an immediate cessation of gas release after valve closure. Instead, Entergy conservatively assumed a full bore release from the pipeline continues for another 2 to 3 minutes after valve closure. Entergy therefore assumed the natural gas release, following an assumed catastrophic failure of the 42-inch pipeline, would actually continue for 5 to 6 minutes.

Please let us know if you have any further questions.

2

IPEC pipeline blast analysis talking points:

1. The staff performed independent confirmatory analysis to evaluate proposed pipeline Impacts from both probabilistic and deterministic pE~rspective. The probability of occurrence of explosion due to the release of methane from pipeline rupture Is calculated to less than 1.0E-07, and minimum safe distance to 1psi overpressure due to potential explosion Is less than the actual distance to the nearest safety related Structure, System and Component (SSC). The ana1lysis is performed with conservative assumptions and rationale using methodology given as follows:

(a). NRC Regulatory Gulde, RG 1.91, Evaluations of Explosions Postulated to Occur Nearby Facilities on Transportation Routes Near N1uclear Power Plants" methodology, (b), NRC NUREG-0800,"Standard Review Plan", Section 2.2.3,"Evaluation of Potential Accidents,

(c). Using the ALOHA (Areal Locations of Hazardous Atmospheres) computer model developed by EPA/NOAA for Emergency Planning and preparedness evaluations.

ALOHA models key hazards overpressure (explosi1on blast force), thermal radiation(heat), flammability(fire) related to chemical releases that result in fires or explosions.

Using conservative meteorological conditions and pipeline characteristics, the amount of methane released is calculated using ALOHA modi:!I and further RG 1.91 equations are used to calculate distance to 1 psi overpressure. The calculated minimum safe distance is less than the actual distance to nearest safety related Structure, System and Components (SSC) inside Security Owner Controtlied Area (SOCA). Flat terrain is conservatively considered in the analysis.

2. The proposed pipeline is much farther away from the plant than the existing pipeline.

3 Using ALOHA model it is also determined that no 1 psi overpressure due to vapor lu e ex loslon, no potential fire damage, and also there no thermal radiation level of (tJ)(7)(t l iti)(7lW) extended to any safety related SSC insldu SOCA.

4. In addition to deterministic analysis, a probabilitytcposure due to pipeline failure is determined based on Pipeline Hazardous Materials; Safety Administration (PHMSA) data, and also published information from "Handbo,ok of Chemical Hazards Analysis Procedures" using conservative assumptions to be less than 1.0E-7 per year, and therefore, is not identified as a design basis event. A design basis event is defined as the event which has probability of greater than 1. OE-7 having radiological dose in excess of 10 CFR 50.34(a)(1). Hence, it is concluded that t:he pipe failure resulting in a methane

release from tne proposea p1pe11ne near IPEC would not pose any increased risk to IPEC or would not reduce any further the existing safety margins.

Tammara, Seshagiri From:

Sent:

To:

Subject:

Palmrose, Donald Friday, December OS, 2014 8;47 AM Mccoppin, Michael; Tammara, Seshagiri Algonquin Gas Transmission pipeline expansion I think this Accufacts is the company I had seen in the prior article.

Algonquin Pipeline Expansion Opponents Suggest Threat To Safety At Indian Point Plant. The f rt1el ~~C uc; ~e r al (12/41 Lungariello, 13K) reports on efforts to stop the Algonquin Gas Transmission pipeline expansion, which will run near Indian Point Energy Center in Buchanan and meme posted by the group Stop the Algonquin Pipeline Expansion, or SAPE, to its Facebook page showing Homer Simpson with his hands to his head and his eyes wide as he fooks down at the controls of a nuclear power plant." The meme continues, "Indian Point & Spectra AIM Project -

What could go wrong." The opposition effort persists even though Indian Point owner Entergy and the Nuclear Regulatory Commission say "expanding portions of the pipeline from 26 inches to 42 inches in diameter wouldn't pose an increased safety risk." SAPE points to a recent report from Richard B. Kuprewicz, of Accufacts, that asserted that "the safety evaluation and analysis of the risks to the nuclear generators {were] 'seriously deficient and inadequate."'

Donald Palmrose, PhD Sr. Reactor Engineer NRO/DSEA/RPAC NRR/OSS/SRXB 301-415-3803 T7-F38 1

Tammara, Seshagiri From:

Sent:

To;

Subject:

Tifft, Doug Monday, December 08, 2014 2:20 PM Trapp, James; Lorson, Raymond; Krohn, Paul; Burritt, Arthuri Mccarver, Sammy; Tammara, Seshagiri; McCoppin1 Michael; Well, Jenny; Dimltfladls, Anthony; Pickett, Douglas RE: outline of tomorrow's call And h,ere is the phone bridge information:

Dial in Number: 888-790-3152 Passcode:~

From: Tifft, Doug Sent: Monday, December 08, 2014 1:57 PM To: Trapp, James; Lorson, Raymond; Krohn, Paul; Burritt, Arthur; Mccarver, Sammy; Tammara, Seshagiri; Mccoppin, Michael; Weil, Jenny; Dimitriadisr Anthony; Pickett, Douglas

Subject:

outline of tomorrow's call Outline for tomorrow's 2pm call with Assemblywoman Galef and Congressional Delegation.

Open call with introductions. - D. Tifft Discuss sensitive nature of the NRC's Independent analysis and that the reason we cannot publicly release the analysis is because it could be helpful to an adversary that was planning an explosive attack on the site. - D. Tifft Turn call over to Sammy to discuss his independent inspection. Discuss watkdown of proposed pipeline path and measured distances to Indian Point structures. Describe location of proposed pipe and topography of the area. Note that the new pipe is further from plant than existing pipe and one of the two existing lines near the site will be retired in place.

Turn call over to NRO to discuss the independent analysis performed using the information obtained through our inspection. Discuss our conclusion that safety related equipment would not be affected. Note that we did conclude other equipment could be impacted by a worst case explosion of the pipeline. However, there are analyzed events (tornado, earthquake, etc) that would also cause a loss of that same equipment. Therefore procedures are already in place to use backup systems should the affected equipment become unavailable.

Turn call back over to Sammy to address his review of Entergy's subject matter experts qualifications.

Respond to questions.

§'~~

Regional State Liaison Officer Office~ 610-337-6918 Cell: l(lJ)/f,)

I

IPEC pipeline blast analysis talking points:

1. The staff performed independent confirmatory anal~rsis with conservative assumptions and rationale using NRC RG 1.91 methodology andl also using the ALOHA computer model developed by EPA/NOAA for Emergency preparedness evaluations. Using conservative meteorological conditions and pipeline* characteristics, the amount of methane released is calculated using ALOHA mode1l and further RG 1.91 equations are used to calculate distance to 1 psi overpressure. The calculated minimum safe distance is less than the actual distance to nearest safety rel:ated Structure, System and Components (SSC) inside Security Owner Controlled Area (SOCA). Flat terrain is conservatively considered in the analysis.

2. The proposed pipeline is much farther away from the plant than the existing pipeline.

3. Using ALOHA model it is also determined that no 1 psi overpressure due to vapor plume ex losion, no potential fire damage, and also there ino thermal radiation level of (b)(7)(F)

(b)(l)(F) extended to any safety related SSC inside SOCA.

In addition to d~ ermrnistic-ana)ysis, (pr~ability exposure due to pipeline failure is determined basectorrPrpetine Hazardous rvr~ ertafs Safety Administration (PHMSA) data, and also published information from "Handbook of Chemical Hazards Analysis Procedures" using conservative assumptions to be lless than 1.0E-7 per year, and therefore, is not identified as a design basis event. A design basis event is defined as the event which has probability of greater than 1.0E-7 having radiological dose in excess of 10 CFR 50.34(a)(1 ). Hence, it is concluded that the pipe failure resulting in a methane release from the proposed pipeline near IPEC would not reduce any further the existing safety margins.

tJ&-

-S/lP ~°'

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- Al\\)~\\A-

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Thermal Radiation at Point AL

_ O_H_A_ 5 41 -t Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user speci ied)

Chemical Name: METHANE Building Air Exchanges Per Hour: 0.50 (enclosed office)

THREAT AT POI N'l':

Model Run : No Model Given Thermal Radiat'on Estimates at the point:

Downwind: 1580 feec Off Center ine: 0. feet Max Thermal Radiation: (b)(l)(F)

W/ (sq m)

(b)(7)(F) 11.t Point:

Downwind: 1580 feet Off Cencarline: 0. :e2c

Thermal Radiacion Threat Zone Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specified)

Chemical Name: METHANE Wind: j._(b_l(_7)_(F_l ____ ~I from E at 3 meters THREAT ZONE:

Threat Modeled: Thermal radiation from e

*re

~LO I

~~nge~ ~

~~b]~)(F~W/( sq ml I~ 2nd degree b ms w. h'n ro s Yellow: L_I (2.0 kW/(sq m) = pa

• n w' hin.0 sec)

(b)(7)(F)

Thennal Radiation a Point

'l'ime: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> BDT (".lser specified)

Chemical Name: M.EThANE Bu ' lding Air Exchanges ?er Hor: 0.50 (enclosed ofticel THREAT AT POINT :

Model Run No odel Given Thermal Radiacion Estimates at the point :

Downw'nd: L580 fe~t Off Cencerl

• ne: Q _ f eet Max 1' errnal ~adiaLion: 4. 05 kW/ { sq in)

(b}(7)(F}

At Peine:

Downwi nd: 1580 feet Of f Centerline: 0. feet t

'!/'

ALOHA 5.4.1

Thennal Radiation Th eat Zone (b)(l)(F)

Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specifiea)

Chemical arne: METHANE Wind: ~!(b_)(_7)(_F_) ___ __,! from Ea 3 meters THREAT ZONE:

Threat Modeled:

Red (b)(/)(F)

Orange:

Yellow:

Thermal radiation from jet fire

~.}~}(~W/ (sq m) t 2nd degree burns withln 60 sec)

(2.0 kW/(sq m)

~ pain ~ithin 60 sec)

-4.--

.. ~

Tammara, Seshagiri From:

Sent:

To:

Subject:

Attachments:

tha From: Tammara, Seshaglri Mccoppin, Michael Wednesday, October 15, 2014 5:17 PM Tammara, Seshagiri RE: Confirmatory Hazard Analysis for IPEC 50.59 Confirmatory _ofJPEC_AIM_HazardAnalysis.docx Sent: Wednesday, October 15, 2014 4;35 PM To: Mccoppin, Michael

Subject:

Confirmatory Hazard Analysis for IPEC 50.59 Mike*

Attached is the summary report, I wish to send it out tomorrow. Please review/comment and correct as appropriate. Then I will formally will send.

Thanks, Rao J

SEIQSI I 111!

!H!Ol!!J"I~ Aiila#.iliD 1e1rmm OitON Safety Review and Confirmatory Analysls of Entergy's 10 CFR 50.59 Safety Evaluation For Algonquin incremental Market (AIM) Project at Indian Point Energy Center (IPEC)

Introduction Algonquin Gas Transmission, LLC (Algonquin) pfoposes an Installation of new 42-lnch diameter plpellne near the southern boundary of IPEC for the transport of natural gas as part of the AIM ProJect, to replace the existing 26-inch pipeline n vicinity of IPEC, which will remain In place but idled._ Entergy prepared a 1 0 CFR 50.59 Safety Evaluation (Reference 1) related to the proposed AIM Project with an enclosure "Hazards Analysis" (Reference 2), The 1 O CFR 50.59 safety evaluation and enclosure covered the consequences of ~

postulated fire and explosion following release of natural gas from the proposed new (southern route) AIM Project 42-lnch pipeline south of IPEC and determined exposure rates associated with fallute of tnat proposed 42-lnch natural gas pipeline Based on the hazards analysis and also accounting for the pipeline design and installation enhancements, Entergy has concluded that the proposed AIM Project poses no increased risks to IPEC and there is no significant reduction In the margin of safety, Therefore, Entergy further concluded that the change in the design basis external hazards analysis associated with the proposed AIM Prqjeot does not require prior NRC approval.

The NROIDSEA/RPAC Staff at NRC Ha 1Jq11 r1a has reviewed Entergy's hazards anatys s tt,at supports the 10 CFR50.59 Safety Evaluatioo related to tmtAIM Project, by performing independent conflrmat,ory calculations to determine whether or not the licensee's conclusion Is reasonable and acceptable, and also to ascertain that there Is adequate reasonable assurance *of safe operation of the plant or safe s11utdown of the plant.

Summary of Evaluation The staff has reviewed Entergy's "Hazafd Analysis' supporting the 10 CFR 50.59 Safety Evaluatio[l related to the AIM Pro1ect. Entergy evaluated potential hazards lo safety-related structures, systems and components (SSCs) and also SSCs important to safety (SSC ITS) using reasonable assumptions and rationale Entergy's methodology Is appropriate and acceptable._ The staff has performed Independent contlrmatory calculatlons with conseNathle assumptions and rationale using RG 1.91 methodology and also using the ALOHA model for vapor plume explosion. The staff also calculated the frequency of potential pipe line failure and determined that t'1ere Is no addlt onal potential r1sk to the safe operation of the IPEC units.

Based on the rev ew of the hazards analysis provided as part of Entergy's 1 0 CFR 50,59 Safety Evaluation, and the staff's independent confirmatory calculation results using conservative assumptions and rationale, the staff concludes that (1) no 1 psi overpressure is extended to any safety-related SSC Inside the Security Owner Co trol Area SOCA (h)(/)(Fi

~ owever, near y SSC TS would be a eoted, because the calculated m nimum safe distances to the Impacts are exceeded The staff finds that the Impacts lo the SSC ITS from the proposed new 42-nch pipellne are bounded by ttie Impacts from low probability events of extreme natural phenomena (Including seismic activity, tornado winds, and hurricanes) which have been assessed end already addressed ln the lndlan Point Units 2 and 3 UFSARs. JllE.!'..Gloud flash fire may occur aloft and burn very rapidly In L few seconds, without affecting any safety-related SSCs or equipment, and the existing margin of safety 1s not expected to be reduced due to ~ potential rupture of the proposed AIM Project pipeline near IPEC.

The staff also finds that the applicant's conclusions, that the potential rupture of the proposed AIM Project SFMSIII\\JE SEC! IRIIY RSI 0750 IMEORII0IIODI

8Dl&ll1Vi 8i81!1FlllV Rilel,liB IPIF8AM11,'18H plpetlne near IPEC poses no threat to safe operation of the plant or safe shutdown of the plant are reasonable arid acceptable, and also comparable to the staff's conclusions.

Technical Evaluation The staff's independent confirmatory analysis was performed based on th~ rupture of the proposed new 42-inch natural gas pipeline consls11ng of about 3 miles between lsolatlon valves, or whloh the enhanced section of pipeline length Is Identified to be -J935 *ft., located along the southern route near IPEC. The analys s assumed that rupture or the natural gas pipeline may result In an unconnned explosion or jet flame at the source, delayed vapor cloud fire, or vapor cloud explosion. Missile generation may also accompany the I

rupture/explosion._ For the assessment of an unconfined explosion, RG 1.91 (Reference 3) methodology was used to calculate the minimum safe distance. For the Jet flame, cloud fire, and vapor cloud exploslon, the ALOHA chemical release modeling computer code (Reference 4) Is used to determine the hazard Impact distances Which are compared with the actual distances at IPEC to stru~ures, systems and components (SSCs) related to safety or SSCs important to safety (SSC ITS), as listed ln Reference 2, Table 1, In order to I assess the impact potential. ALOHA is run using the appropriate source term (amount of methane released) for the scenario considered, using conservative meteorological conditions !(b}(7)(F)

I l/t>)/7)/F) t cloud cover of 0.5 and relative humidity of 50%. Open country ground roughness conditions modeling assumptions were chosen.

. EXPLOSION The ALOHA model for explosion scenario 1 conservatively assumed that the pipe rupt4re occurred at the rar end of the pipe line above the surface. considering the length or pipeline to be 3 miles, l(b)(l)(F) l ti> l( l \\ fl tat a maximum opera1ing pressure of 850 psig. The ALOHA calcul ation for this scenario resulted in a maximum sustained methane release rate of 256,000 pounds/min, and estlm.ated total release amount of 354,651 pounds averaged over 9 minutes, conslderfng manual closure of !he isolation valves within 3 minutes. Conservatively assuming the maximum release over one minute (256,000 pounds of methane), and determining the TNT equivalent amount w1th a yield factor o.L-...j~~

with equation given below, the mlnlmum safe distance (d) to 1 psi overpressure ls calculated to be (b)(7) using RG 1.91 methodology as follows:

\\Fl WTNT== (Mf

• DHC

• Y)/4500 d= 45 * (w) 113 where WTNT= TNT equivalent Mass, kg Mf

= Mass of vapor, kg OHC = Heat of combustion. kj/kg (50030)

Y

= Yield Factor (0.05) where d= minimum safe distance (ft) to 1 psi overpressure w=TNTequlvalent mass in pounds This calculated minimum safe distance of 2351 ft is smaller than the actual distance of 2363 fl to the SOCA (Security Ow11er Coritrol Area) from the pipeline at the far end above surface or 2988 ft to the nearest safety-related SSC (nearest safety-related SSC inside SOCA IJB sfJ!L, about~:rn from the edge of the

&li*l&lil11lii filii£WR!i>< Rli...,ililill OlflilJRHfillilJH Formattll!d1 No underline

S21431 I I OE - SEC URI I i KELA I Eb I.Ci Oi(MA,1et*

SOCA) and therefore 1 psi overpressure is not expected at any safety-related SSC Inside the SOCA from a potential rupture and explosion at the far end of !b.stpipellne lal:.3te above lh surface._ However, as the calculated minimum safe distance of 2351 ft Is larger than the actual distances lo all SSC ITS, they may experience greater than 1 psi overpressure. Therefore, the SSC ITS would be impacted. Nevertheless, their Impacts are bounded by the severe/beyond design basis accidents considered as part of low probability events such as natural phenomena that include seismic, hurricane and tornado events including Loss of Offsite Power and Station Black Out (S80) considerations with design of redundant systems. engineering safeguards and mlligatfo11 measures In the plant UFSARs. The frequency of exposure due to fallure of these SSC ITS from potential rupture of AJM Project is also briefly presented later in this report to address Whether the margin of safely Is reduced or compromised due to rupture of AIM Project

[ Assumlng _ 5% yield factor for & unconfined methane explosion (as given in RG 1.91 ), the methane amount detem,ined from the maximum 256,000 pounds of methane released over one minute (determined from the ALOHA ruh) Is used as an instantaneous methane release to simulate the vapor cloud dispersion. transport and delayed explosion (conservatively assuming congestion similar lo that from physical structures and dense forest in the area) with the ALOHA model. The model determined minimum safe distance to 1 psi overpressure due to delayed vapor cloud explosion ts 3054 ft, and is slightly higher (by 66 ft) than the actual distance of I l(b)(7)(F)

I oreover, the SSCs are generally designed to withstand n ov~rpressure o ps.

• 11 1 as methane Is buoyant and quickly rises alo~. disperses rather rapldly, and,.....,_............_ _____________ __.

I

!(b)(/)(1-l

!Therefore, the ALOHA model was rerun with the same Input except with an assumption of no congestion in the area. The ALOHA model resulted In no vapor cloud explosion of 1 psi overpressure at any distance due to potentlal Ignition. The potential pipe rupture underground al the enhanced section of the pipeline. would be expected to result In a slower methane release rate, and thereby

~~hav_ pq~nt*all~ much lower lmpacts than those determined as above.

JET FIRE The ALOHA model was run conservatively assuming that the f!i iJrlilillZIU\\e occurred at 'Os far end of the pipe line above the surface, considering the length of pipellne to be 3 mlles,._(t_i)_(l_)(r_) ____ __.

fit,}(7HF/

~t a maximum operating pressure of 850 psig. Methane is assumed to be re eased from the rujltured pipe as a flammable gas and, burning.* The ALOHA model run resulted in a maximum burn rate o~fb)Wff)

~

I and an estimated total amount burned of :354,651 pounds averaged over 9 minutes, fill!J_ considering manual closure of the isolation valves within 3 minutes. The distances (Table 2) to thermal radiation levels of !(b)(?)(i) 15.0 kW/m2, and 2,0 kW/m2 calculated by ALOHA arel(b )(7)( F) respectively.

The ALOHA model was also run conservatively assuming that the rupture of pipe occurred in the middle of the pipe located underground at the enhanced section Identified close to the SOCA, con~iderjgg half tbe teogth pf the i eline between isolation valves 1.5 miles) on each side of the rupture location,!(h)(7)(F) b) 7 F at a maximum operating pressure of 850 psig. Methane is assumed to be released from ll!... Nptured pipe,segment as a burning flammable gas. The ALOHA model run resulted in a maximum burn rate of lfb}(D{Fl j and consider'fng closure of the Isolation valves within 3 minutes. The calculated distances 8!1401tlte:

SECOAII I R2CAIED il!JFORMAIION

(Table 2) to the them,al radiation levels or (1!)(7)(f) respectively.

5 0 kW/m2, 2.0 kWlm2 are (b)(7)(F)

The distances determined to the thermal radiation level of (b)(7)(F) wh ch has a potential to damage structures and eripment) due to potential p!J)e rupture at ar en o e plpeltne or in middle of the plpe0ne are

' (b)(7l(F) respectively Both of these determined distances are smaller than the actual distances of 2363 fl a{ld 1580 ft, respectively, to the SOCA and therefore. jet fire would not pose any adVerse effect on SSCs related to safety. However, it may Impact some of the SSC ITS as the radiation level of!(b}(7)(Fl

!may be exceeded for some SSC ITS outside of the SOCA. Nevertheless, 1he Impacts lo SSC ITS are bounded by the severe/b yond design basis accidents cons dared as part of seismic and tornado events covering Station Black Out (SBO) and Loss of Offs te Power considerations with design of redundant systems. engineering safeguards and mitigation measures already addressed In the plant UFSARs, CLOUD FIRE I Tile ALOHA model was run conseivatlvel~ assumm9 t.tiat the rupture or p1fi, occurred at=== far ena ol the ptJ)e line above the surface, considering the length or pipeline lo be 3 miles, !(bl \\(Fl I

!(b)(7~F~

pta maximum operating pressure of 850 psig. T e ALOHA model run resu e in a maximum sustained release rate or 256,000 pounds/min. and ao estimated total release amoun of 354,651 pounds averaged over 9 minutes, considering manual closure of the Isolation valves within 3 minutes. Conservatively assumlng the maximl.Jrn release rate over one minute, 256.000 pounds of methane (determined from the ALOHA run) is used as an instantaneous release over one minute, to simulate the vapor cloud dispersion, transport to determine the distance to reach the methane lowerexplos1 e limit {LEL) of 44.000 ppm. Tile ALOHA model determined e distance of 1.8 miles to reach the LEL This estimated distance would bound the potential distance to La._LEL from L rupture in the middle of pipe in the enhanced area burled underground~ Even though the methane plume travels.,

a long distance, It Is buoyant and rises alolt quickly and, therefore, also bums rather rapidly 1n seconds far above tlie ground without sustaining and without c:hallenglng the structures a,,d components. if enough oxygen 1s available. Therefore, the impact from cloud fire on SSCs and equipment 1s not considered challenged.

DETERMINATION OF EXPOSURE RATE FOR FAILURE OF THE AIM PROJECT PIPELINE NEAR IPEC Based on Pipeline Hazardous Materials Safety Admimstratfon (PHMSA) data (www.phmsa.do1 gov), and also published information from ' Handbool( otChemlcal Hazaitls Analysis Procedures* (Reference5), !he accident rate of pipes greater than 20 inches diameter is about 5 x 10.. /mile-yr.* Assuming 3 miles of AIM Prefect pipeline near IPEC, the accident rate Is determined to be 1.5 x 1 ~/yr. Based on the inl'ormaUon 1n these references, estimating 1 percent of accidents result in a complete pipe break or 100 percent instantaneous release, and assuming also only 5 peroent of the time at the released gas becomes ignited leading to potential explosion, the explosion frequency for the AIM project plpeline near IPEC ls calculated to be about 7.5 x 10 7 /yr If this release Is due to _1 _ underground pipe, the frequency of explosion win be further reduced by at least an order of magnitude. In addition, the frequency of large radioacuvity reJease from the reactor due to the frequency of the above pipe rupture event. considenng operating reactor conditional core damage rrequency (CCDF), WQU1d be at least few orders of magnitude tower, and therefore would not be Identified as a design basis event Therefore, ii is concluded that !he pipe failure resulting in a metn-ane release from ~

proposed AIM Project near IPEC, would not reduce any further the existing safety margins. and would not pose a tllreat to the safe operation of the plant or safe shutdown.

SENSI I IOE - SECOKI I, ktdtf~ l!~F8,.M"1fl8U

&1ii,1&ri;11;1e 81?61!1"""' R!!UtlEU 1111 ORMAIIOl4 CO CL,slON Based on the review of the hazards analysis pro\\lided as part of Enlergy*s io CFR 50.59 Saf'ety Evaluation related to the AIM Project near IPEC, and staff's independent confilm.atory calculation results using conservative assumptions and rationale the stall concludes that no 1 ressure is extended to an safety-related SSC inside the SOCA (b)(7)(F}

t* (7 (f)

However, nearby SSC ITS wou be affected, as e ca,cu ated m nimum safe distances to the Impacts are exceeded, but these impacts are-bounded by the impacts from low probability events of extreme natural phenomena that include seismtc. tornado winds, hUnicanes Which ha11e been assessed and already addres ed in UFSAR. Cloud fla h fire may occur aloft and bum very rapidly in few seconds, without affecting any safety related SSCs or equipment, and the existing margin of safety Is not expected to be reduced due to potential rupture of the proposed AIM Project. pipeline near IPEC. The staff also finds that the applicant's conclusions tha the potential rupture of the proposed AIM Project pipeline near IPEC poses no threat to safe operation of the plant or safe shutdown of the plant are reasonable and acx:eptable.

The staff's review finds that the hazards analysis supporting the lioensee*s 10 CFR 50.59 safely evaluation is appropriate and shows that lhere is not more than a minimal increase to lhe Ukellhood of occurrence or consequences of damage to a safety-related SSC or SSC ITS, when comparad lo the current hazards analysis In the plant UFSARs.

REFERENCES

1.

Entergy, *10 CFR 50.59 Safety Evaluation and SupPorting Analyses Prepared in Response to the Algonquin Incremental Market Natural Gas Project Indian Point Nuclear Generating Units Nos. 2 &

3

• NL-14-106, August 21. 2014. ML14245A110.

2.

Entergy, "Hazards Analysis" Enclosure to NL-14-106, August 21. 2014. ML 14245Ai 11 (Non-public)

3.

US Nuclear Regulatory Commission. Regulatory Guide 1.91, "Evaluations of Explosions Postulated to Occur at nearby Facllitles end on Transportation Routes Near Nuclear Power Plants

• Revision 2, April 2013.

4.

us EPA. NOAA: ALOHA User's Manual ~ February 2007.

5.

FEMA, US DOT, US EPA "Handbook of Chemical Hazard Analysis Procedufes

• SFNSIIll'F SSC' IR'IY RFlaU60 IPIF&Rl\\1Jli,IBU

8BJ&lilwl?S&

EiGI fAITY Bil AXED INEORN0IION SStJSIIIVS S&GWAI~ Ail-'ll!& IIJFiflf,1"'401*

Piedmont Natural Gas Material Safety Data Sheet

1.

CHEMICAL PRODUCT AND COMPANY IDENTIFICATION (rev. 9..04)

Trade Number: Natural Gas (odorized)

CAS Number: 68410-63-9 Synonyms: Natural Gas (dry), Natural Gas (CNG), Methane. Pipeline Spec Gas, Processed Gas, Residue Gas, Sweet Natural Gas, Treated Gas Use/Description: Fuel for combustion applications, raw material for chemical reactions Corporate Company Emergency Telephone Numbers Identification Identification Physical Malling Piedmont Natural Gas Piedmont Natural Gas Safety Officer [8:00 am - 5:00 pm]: *1 (704)-731-4376 1915 Rexford Road PO Box 33068 CIC: 1(704) 525-3882 Charlotte, NC 28211 Charlotte NC 28233 Gas Control 124 houri: 1(704} 731-4253 or 1(800)-694-0750

2.

COMPOSITION/INFORMATION ON INGREDIENTS (rev. 9-04)

Components CAS No, Mole3/4 Exposure Limits ACGIH TLV (ppm)

OSHA PEL loom)

~

None established by OSHA or ACGIH Methane 78-82-B 87.0-86%

Slm11l11 aschvKlant. l!!(p<J&Ure llmtt&d bv owoen and nammabllltY Balance Gases*

Ethane 78-84*0 1,8-5,1%

None established by OSHA or ACGIH Slmole aschvxlant: excosure limited 011 oxvaen and flammabllltv Prooane 74-98-6 0.1-1.6%

2600 j TWA 1000 TWA Nitrogen 7727-37-9 1.3*5,6 1000 l TWA Carboo 124-3~9 0, -,.0 5000 I TWA 5000 TWA Dioxide NOTE: No permlsslble exposure llmfts (PEL) or threshold llmll values (TL V) exist for natural gas. The above listing is a summary of the gases In natural gas Which can be round al concentrations greater lhan 1 mole %. Because natural gas is a natural product, composition can vary greatly.

3.

HAZARDS IDENTIFICATION (rev. 9-04)

EMERGENCY OVERVIEW DANGERI EXTREMELY FLAMMABLE GAS - MAY CAUSE FLASH FIRE OR EXPLOSION!!

Keep away from heat, sparks, flames, or other sources of ignition (e.g.

static electrici ilot Ii hts mechanical / electrical e ui ment Page 1 of 9 Revision Date: 9/24/2004

Natural Gas ID No. 1971 ERG.115 WARNING: This product is a simple asphyxlant. In high concentrations it will displace oxygen from the breathing atmosphere, particularly in confined spaces. Signs of asphyxiation will be noticed when oxygen is reduced to below 16%, and may occur in several stages: Symptoms may include rapid breathing and pulse rate, headache, dizziness, vfsual disturbances, mental confusion, incoordination, mood changes, muscular weakness, tremors, cyanosis, narcosis and numbness of the extremities. Unconsciousness leading to central nervous system Injury and possibly death will occur when the atmospheric oxygen concentration is reduced to about 6% to 8% or less.

WARNING: The burning of any hydrocarbon as a fuel in an area without adequate ventilation may result in hazardous levels of combustion products, includlog carbon monoxide, and Inadequate oxygen levels, which may cause unconsciousness, suffocation, and death,

4.

HEALTH HAZARDS IDENTIFICATION (rev. 9-04)

Potential Health Effects Note: Natural gas in its gaseous state under normal conditions and at very low concentrations, does not present an Inhalation, ingestion or skin hazard.

At high concentrations, natural gas Will reduce the available oxygen in the a.r, thus resulting in symptoms of headache, nausea, dizziness, fatigue and possibly coma and / or death, 111 situations where natural gas is not completely combusted, carbon monoxide will accumulate which can cause an explosion hazard and a suffocation hazard.

Special note:

Using natural gas for cutting, annealing, as a chemical ingredient, or as a raw material In chemical manufacturing may cause exposure to other unknown* hazards. See manufacturer of other materials for potential exposures Primary Route of Exposure Inhalation.

filY Not irritating. Under most circumstances, exposure to natural gas will not affect the eyes. Use of natural gas to heat, cut, or anneal materials should require the use of safety glasses to insure that no foreign materials enter the eye,

~

Not irritating, When natural gas is being combusted, heat is generated which may burn the skin. Under most other circumstances, exposure to natural gas will not affect the skin. Use of natural gas to heat, cut, or anneal materials may require the use of protective clothing to insure that no parts of the body are burned or foreign materials enter the skin.

INGESTION Risk of Ingestion Is extremely unlikely.

INHALATION This product is considered to be non-toxic by Inhalation.

The effects of inhalation of high concentrations may cause the same effects as asphyxiation. This includes central nervous system depression such as dizziness, drowsiness, headache, and similar narcotic symptoms, but no long-term effects if removed from E!xpo,sure area. Numbness, a *tchllly" feeling, and vomiting have been reported from accidental exposures to high concentrations.

Carbon Monoxide poisoning can occur as a result of poor installation, poor maintenance or failure or damage to an appliance in service, the fuel is not burned properly, or when rooms are poorly ventilated and the carbon monoxide is unable to escape. Carbon monoxide poisoning occurs when carbon monoxide Page 2 of 8 Revision Date: 9/24/2004

Natural Gas ID No. 1971 ERG. 115 enters th.e lungs via the normal breathing mechanism and displacing oxygen from the bloodstream.

Interruption of the normal supply of oxygen puts at risk the functions of the heart, brain and other vital functions of the body.

CHRONIC and CARCINOGENICITY Methane and ethane, the main components of natural gas, are considered practically Inert in terms of physiological effects At high concentrations these materials act as simple asphyxiants and may cause death due to lack of oxygen. Exposure to carbon monoxide concentrations can cause the following:

Concentration of CO in air Inhalation time and toxic develooed 50 parts per million (ppm)

Safety level as specified by the Health and Safety Executive 200PPM Slight headache within 2-3 hours 400 PPM Frontal headache within 1-2 hours, becoming widespread in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 800 PPM Dizziness, nausea, convulsions within 45 minutes, insensible in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1200 PPM Immediately Dangerous to Life and Health (IDLH)

CARCINOGENICITY:

OSHA:NO IARC:NO NTP: NO ACGIH: NO MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE Individuals with pre-existing coriditions of the heart, lungs, and blood may have increased susceptibility to symptoms of asphyxia.

5.

FIRST AID MEASURES (rev. 9*04)

EYES In case of a burn to the eye due to combustion of natural gas, cover eyes to protect from light. Seek immediate medical attention.

During cutting, annealing, or heating materials, dusts or particulates may cause mechanical irritation Including pain, tearing, and redness. Scratching of the cornea can occur If eye is rubbed. Fumes may be irritating. Contact with the heated material may cc1use thermal burns.

SKIN In case of burn due lo combustion of natural gas, seek immediate medical attention.

Contact with heated material or products of combustion may cause thermal burns.

INGESTION Although risk of Ingestion is extremely unlikely, in case of oral exposure, seek immediate medical attention.

INHALATION If exposed to excessive amounts of natural gas due to a leak, remove person to fresh air using proper protective equipment. If person is not breathing, provide artificial respiration. If necessary, provide additional oxygen once breathing is restored if trained to do so, DO NOT USE ANY EQUIPMENT THAT Page 3 of 8 Revision Date: 9/24/2004

Natural Gas ID r-Jo. 1971 ERG.115 MAY SERVE AS A SOURCE OF IGNITION UNTIL NATURAL GAS HAS COMPLETELY DISIPATED.

Seek medical attention immediately.

If exposed to excessive amounts ot carbon monoxide due to products of incomplete combustion, remove person to fresh air using proper protective equipment. If person is not breathing, provide artificial respiration. If necessary, provide additional oxygen once breathing is restored if trained to do so. DO NOT USE ANY EQUIPMENT THAT MAY SERVE AS A SOURCE OF IGNITION UNTIL CARBON MONOXIDE HAS COMPLETELY DISJPATED. Seek medical attention immediately.

6. FIRE FIGHTING MEASURES (rev. 9~04)

FLAMMABLE PROPERTIES: (NFPA Natural Gas)

FLASH POINT:

Flammable ~as AUTOIGNITION POINT:

900-1170 F (482 - 632 °C)

OSHA/NFPA FLAMMABILITY CLASS: FLAMMABLE GAS LOWER EXPLOSIVE LIMIT (%);

3.8 - 6.5 UPPER EXPLOSIVE LIMIT(%):

13 - 17 FIRE ANO EXPLOSION HAZARDS Dangerous fire and explosion hazard when exposed to heat, sparks or flame. Natural gas is lighter than air and may travel long distances to a point of ignition and flash back. Containers containing or which have contained natural gas may explode in heat or fire.

EXTINGUISHING MEDIA To extinguish a natural gas fire, stop the flow of natural gas, use dry chemical, carbon dioxide, halon or water. Special note, the fire should not be extinguished unless flow of gas can be immediately stopped.

FIRE FIGHTING INSTRUCTIONS Gas fires should not be extinguished unless flow of gas can be immediately stopped. Shut off gas source and allow gas to burn out. If spill or leak has not ignited. determine if water spray rnay assist in dispersing gas or vapor to protect personnel attempting to stop leak.

Use water to cool equipment, surfaces and containers exposed to fire and excessive heat. For large fire the use of unmanned hose holders or monitor nozzles may be advantageous to further minimize personnel exposure.

Isolate area, particularly aro\\Jnd ends of storage vessels. Let vessel, tank car or container bum unless leak can be stopped. Withdraw immediately In the event of a rising sound from a venting safety device. Large fires typically require speciafly trained personnel and equipment to isolate and extinguish the fire.

Firefighting activities that may result in potential exposure to high heat, smoke or toxic by-products of combustion should require NIOSH/MSHA-approved pressure-demand self-contained breathing apparatus with full face piece and full protective clothing.

See Section 16 for the NFPA 704 Hazard Rating.

7.

ACCIDENTAL RELEASE MEASURES (rev. 9-04)

ACTIVATE FACILITY'S EMERGENCY RESPONSE PLAN.

EVACUATE NONESSENTIAL PERSONNEL and secure all Ignition sources. No road flares, smoking or flames in hazard area. Consider wind direction, stay upwind, if possible. Evaluate the direction of product travel. Cold vapor cloud may be white, but color will dissipate as cloud disperses - fire and explosion hazard is still present!

Stop the source of the release, If safe to do so. Consider the use of water spray to disperse vapors. Isolate the area until gas has dispersed. Ventilate and gas test area before entering.

Page 4 ofB Revision Date: 9/24/2004

Natural Gas ID No. 1971 ERG. 115

8.

HANDLING AND STORAGE (rev. 9-04)

HANDLING and STORAGE PRECAUTIONS Keep away from flame, sparks and excessive temperatures. Store only ln approved containers. These containers must meet the requirements as specified in 49 CFR 173.302.

Containers should be bonded and ground when filling or discharging. Use only in well ventilated areas. See also applicable OSHA regulations for the handling and storage of this product, including, but not limited to, 29 CFR 1910.110 Storage and Handling of Liquefied Petroleum Gases.

When storing natural gas, use explosion proof or intrinsically safe electrical equipment designed for the atmosphere in accordance with applicable codes, industrial recommended practices, and local, state and federal regulations. Do not smoke or use spark-producing tools in the area of use.

9.

EXPOSURE CONTROLS ANO PERSONAL PROTECTION (rev. 9*-04)

WARNING: The natural gas when combusted releases products of combustion including carbon dioxide, and oxides of nitrogen. If combustion is not complete, natural gas may release carbon monoxide. Where appropriate, use carbon monoxide detectors when burning natural gas to insure that all natural gas is being combusted completely. If the carbon monoxide detector alarms, discontinue use of the appliance until a Piedmont Natural Gas employee or other authorized natural gas techntcian can service the appliance.

ENGINEERING CONTROLS When using gas at home or in an industrial setting1 use adequate ventilation to keep gas concentrations of this product below occupational exposure and flammability limits, particularly in confined spaces.

When appropriate, use explosion-proof equipment and lightihg in classified/controlled areas.

When using natural gas, insure that natural gas concentration has not built up prior to adding ignition source. Failure to insure that natural gas concentration has not built up may result in an explosion.

EYE/FACE PROTECTION When lighting natural gas, use eye protection to protect from burns.

SKIN PROTECTION Where appropriate, wear proper personal protective equipment (PPE) including flame retardant clothing to protect against burns.

RES Pl RA TORY PROTECTION Use a NIOSH/MSHA approved positive-pressure, supplied air respirator with escape bottle or self-contained breathing apparatus (SCBA) for gas concentrations above occupational exposure limits, for potential for uncontrolled release, if exposure levels are not known. high carbon monoxide concentration, or in an oxygen-deficient atmosphere.

HEARING During a high-pressure release, the release may cause a whistling noise. Hearing protection may be required for high-pressure releases of natural gas.

CAUTION: Flammability limits (i.e., explosion hazard) should be considered when assessing the need to expose personnel to concentrations requiring respiratory protection.

Refer lo OSHA 29 CFR 1910.134, ANSI 288.2-1992, NIOSH Respirator Decision Logic, and the manufacturer for additional guidance on respiratory protection selection.

Page 5 of 8 Revision Date: 9/24/2004

Natural Gas

10.

PHYSICAL ANO CHEMICAL PROPERTIES (rev. 9.04)

APPEARANCE Colorless gas The lack of visible gas cloud does not indicate absence of gas.

ODOR ID No. 1971 ERG. 116 Natural gas has a distinctive, disagreeable "natural gas type odor when treated with an odorizing agent (typically < 0.1 % ethyl mercaptan).

BASIC PHYSICAL PROPERTIES (for methane)

BOILING POINT*

-259 °F (* 162 °91 VAPOR PRESSURE:

40 atm. @ -187 F (-86 °C)

VAPOR DENSITY (air = 1 )'

0.6 SPECIFIC GRAVITY (H20 = 1)*

0.4@ -263 °F (-164 °c)

SOLUBILITY (H20):

3.5%

11.

STABILITY AND REACTIVITY (rev. 9-04)

CONDITIONS TO AVOID and INCOMPATIBLE MATERIALS Keep away from strong oxidizers, ignition sources and heat.

STABILITY: Stable. Hazardous polymerization will not occur.

CONDITIONS TO AVOID ahd INCOMPATIBLE MATE~IALS Keep away from strong oxidizers. Oxidizers to avoid Include bromine pentafluoride, oxygen difluoride, and nitrogen trifluoride, and hydrogen peroxide at concentrations greater than 30%.

Thermal decomposition may release toxic oxides of carbon dioxide and carbon monoxide.

Keep away from chlorine gas. Natural gas Will spontaneously ignite when mixed With chlorine gas. In addition, the products of the reaction of methane and chlorine are carbon, hydrogen chloride, and various chlorocarbons. Hydrogen chloride is otherwise known as hydrochloric acid.

HAZARDOUS DECOMPOSITION PRODUCTS Thermal decomposition may release carbon monoxide, carbon dioxide and non-combusted hydrocarbons (smoke).

Chemical decomposition (chlorine) may release carbon and hydrogen chloride.

12.

ECOLOGICAL INFORMATION (rev. 9-04)

This product is expected to exist entirely in the vapor phase ii'\\ ambient air

13.

DISPOSAL CONSIDERATIONS (rev. 9--04)

Consult federal 1 state and local waste regulations to determine appropriate disposal methods.

Page 6 of8 Revision Date: 9/24/2004

Natural Gas ID No. 1971 ERG.115

14.

TRANSPORTATION INFORMATION (rev. 9-04)

PROPER SHIPPING NAME:

HAZARD CLASS:

NATURAL GAS, COMPRESSED (with high methane content) 2.1 DOT IDENTIFICATION NUMBER:

DOT SHIPPING LABEL:

UN 1971 FLAMMABLE GAS CONTAINERS:

AS SPECIFIED IN 49 CFR 173.302, 49 CFR 173.306 OR 49 CFR 173.318 WHERE APPLICABLE.

QUANTITY LIMITATIONS:

AS SPECIFIED IN THE HAZARDOUS MATERIALS TABLE LISTED IN PART 49 OF THE CODE OF FEDERAL REGULATIONS (49 CFR)

PASSENGER AIRCRAFT PASSENGER RAILCAR:

FORBIDDEN l

FORBIDDEN CARGO AIRPLANE:

FORBIDDEN EXCEPT AS SPECIFIED IN THE HAZARDOUS MATERIALS TABLE LISTED IN 49 CFR.

15.

REGULA TORY INFORMATION (rev. 9-04)

U.S. FEDERAL, STATE, and LOCAL REGULATORY INFORMATION This product and its constituents listed herein are on the EPA TSCA Inventory. Any spill or uncontrolled release of this product, including any substantial threat of release, may be subject to federal, state and/or local reporting requirements. This product and/or its constituents may also be subject to other regulations at the state and/or local level. Consult those regulations applicable to your facility/operation.

CERCLA SECTION 103 and SARA SECTION 304 (RELEASE TO THE ENVIRONMENT)

This product does not contain any chemicals subject to the reporting requirements of CERCLA Section 103 or SARA 304. In addition, the CERCLA definition of hazardous substances contains a "petroleum exclusion clause which exempts natural gas and synthetic gas usable for fuel and any indigenous components of such from the CERCLA Section 103 reporting requirements.

SARA SECTION 311/312

• HAZARD CLASSES ACUTE HEALTH CHRONIC HEALTH FIRE SUDDEN RELEASE OF PRESSURE REACTIVE APPLIES APPLIES SARA SECTION 313 - SUPPLIER NOTIFICATION This product does not contain any chemicals subject to the reporting requirements of Section 313 of the Emergency Planning and Community Right-To-Know Act (EPCRA) of 1986 and of 40 CFR 372.

CANADIAN REGULATORY INFORMATION Class A (Compressed Gas) Class B, Division 1 (Flammable Gas)

16.

OTHER INFORMATION (rev. 9..04)

NFPA 704 HAZARD RATING:

HEAL TH:

1 Slight FIRE:

4 Extreme REACTIVITY: 0 Negligible HMIS HAZARD RA TING HEAL TH:

1 Slight FIRE:

4 Severe REACTIVITY: 0 Minimal SUPERSEDES MSDS DATED: none Page 7 of8 Revision Date: 9/24/2004

Natural Gas DISCLAIMER OF EXPRESSED ANO IMPLIED WARRANTIES AND LIABILITY ID No. 1971 ERG. 116 Information preserited herein has been compiled from sources conslderep to be dependable, and Is accurate and reliable to the best of our knowledge and belief, but Is not guaranteed to be so. Since conditions of use are beyond our control, we make no warranties, expre$sed or implied, except those that may be contained In our Written contract of sale or acknov.1edgment. Vendor assumes no responsibility for iniury 10 user or third' persons proximately caused by the material if reasonable safety procedures are not adhered to as stipulated In the data sheet, AddltlonaJly. vendor assumes no responsibility for injury to user or third persons proximately caused by abnormal use ol the material, even,If reasonable safety procedures are followed. Fur1hermore, user assumes the r'lsk fn their use of the material.

The information 1n this Material Safety Data Sheet (MSDS) was obtained from sources which we believe are reliable; however. the information ls provided wi1hou1 any representation ofwairanty, expressed or implied, regarding the accuracy or correctness, The condttlons or methods of handling, storage, and/ or llse of lhe product are beyond our control and may be beyond our knoW1edge. For tl)ls and other reasons, we do nol assume responsibility and expressly disc/aim liability for loss, damage, or expense arising out or or In any way connected Vvith the handling, storage. and / or use or this product Page 8 of8 Revision Date: 9/24/2004

Mccoppin, Michael From:

Sent:

To:

Cc:

Subject:

Miller, Chris Monday, March 16, 2015 10:02 AM Pickett, Douglas; Beasley, Benjamin Mccoppin, Michael FW: found an ALOHA expert for real now 415-3 02-9

___-::::::;=:========r I just spoke with a relatively new employee in DIRS who used to do the ALOHA calcs for industry and submit to NRO. His name is Zachary Hollcraft (Zachary.Hollcraft@nrc.gov. Scott Morris knows you may be asking for him to do a backupcalc review. Also there is someone that Zachary recommended that has experience in Region IV, Natasha Greene. She works in DRS, and I have reached out to Tony Vegel by e-mail to see if she could be used as a resource 1f needed.

From*: Marshall, Jane Sent: Tuesday, March 03, 2015 4:03 PM To: M Iller, Chris

Subject:

found an ALOHA expert for real now Mark.w.miller@noaa.gov; work-(206)526-6272, unfortunately he won't be back in the office until Monday. He was here at NRC today also - so close...

(Type text]

!!U91",E 31!:CbRlf I RELAI Eb li4POAIO/AIIOIQ Safety Review and Confirmatory Analysis of Entergy's 10 CFR 50.59 Safety Evaluation For Algonquin Incremental Market (AIM) Project at Indian Point Energy Center (IPEC)

Introduction (Type text]

Algonquin Gas Transrnlssion, LLC {Algonquin) proposes an lnstallaUon of new 42-lnch diameter pipeline near the southern boundary of IPEC for the transport of natural gas as part of the AIM Project, to replace the existing 26*inch pipeline in vicinity of IPEC. which will remain In place bul Idled. Entergy prepared a 10 CFR 50.59 Safety Evalualfon (Reference 1) relatecl to the proposed AIM Project with an enclosure "Hazards Analysis" (Reference 2), The 10 CFR 50.59 ~afety evaluation and enclosul'e covered the consequences of postulated fire and explosion following release of natural gas from the proposed new (southern route) AIM Project 42-inch pipeline south of IPEC and determined exposure rates associated with failure of that proposed 42-lnch natural gas p pellne. Based on the hazards analysis and al50 accounting for the pipeline deslgn and installation enhancements, Entergy has concluded that the proposed AIM Project poses no Tncreased risks to IPEC and there s no significant reduction in the margin of safety. Tl1erefore, Entergy further concluded that the change in the design basis external hazards analysis associated with the proposed AIM Project does not I"t?qulre prior NRC approval.

The NRC Staff has reviewed Entergy's hazards analysis that supports the 10 CFR 50,59 Safety Evaluation related 10 AIM ProJect, by performing independent confirmatory calculations to determine whether or not the licensee's conclusion is reasonable and acceptable, and also to ascertain thal there Is adequate reasonable assurance of safe operation of the plant or safe shutdown of the plant Summary of Evaluation The staff has reviewed Entergy's 'Hazard Analysis" supporting the 10 CFR 50.59 Safety Evaluation related 10 the AIM Project Entergy evaluated potential hazards to safety-related structures, systems and components (SSCs) and also SSCs Important to safety (SSC ITS) using reasonable assumptions and rallonale. Entergy's methodology is appropriate and acceptable. The staff has performed independent confirmatory calculations with conservative assumptions and rationale using RG 1 _91 methodology and also using the ALOHA model for vapor plume explosion. The staff also calculated the frequency of potential pipe line fa!lure and determined that there Is no addlUonal potenUal risk to the safe operaUon of the IPEC units.

Based on the review of the hazards analysis provided as part of Entergy's 10 CFR 50.59 Safety Evaluation, and thestarf's independent confirmatory calculation results using conservative assumptions and rationale, the staff concludes that ( 1) no 1 psi overpressure ls extended to an safety-related SSC Inside the Securi Owner Control Area (SOCA), and (hl F

However, nearoy SSC ITS would be affected, because the calculated minimum sa e,stances to the impacts are exceeded The staff finds that the impacts to the SSC ITS from the proposed new 42-inch pipeline are bounded by the Impacts from low probability events of extreme nc1tural phenomena (includling seismic activity, tornado winds. and hurricanes) which have been assessed and already addressed in the tndlan Point Units 2 and 3 UFSARs. Cloud flash fire may occur aloft and burn very rapidly In few seconds, without affecting any safety-related SSCs or equipment, and the existing margin ot safety Is not expected to be reduced due to potential rupture of the proposed AIM Project pipeline near IPEC The staff also finds that the applicant's conclusions, that the potential rupture of the proposed AIM Project pipenne near IPEC poses no threat to safe operation of the plant or safe snutdown of the plant, are reasonable end acceptable, and also comparable to he staff's conclusions.

SSMSfil\\15 SFCIIRIIY REI 0150 IMSARMOIIAM Comment [n,I111]: Con~ld01'.-.+iother to I

identify that the st.;ff 1n queslion is NROIOSENRPAC slpff I

Comment [ml112]'1roo ll1a1 looked only al I 11811)\\y-<elallld SSC. e,,d SSC ITS? (d1dn'I IOO at non-safely SSCs)

I C:Ollll!ilel!t (mlh3J I I imnk 11".! 80Q 1P3 nlvi soparate UFSAR!l AlthQu!)!1, lhey probably lilly Iha same 111,rig about slta hal.llrd~

[Type text)

SStJGfTJ'Ci

£5Cl'NRIIY REI AISP INFABMAilON

[Type texQ Technical Evaluation The staff's Independent oonfinnatory analysis was performed based on rupture of the proposed new 42-inch natural gas plpellne consisting of about 3 miles between Isolation valves, of which !the enhanced section of pipeline length is Identified to be 3935ft, located along the southern route near IPEC. The analysis assumed that rupture of the natural gas pipeline niay result In an unconfined explosion or j1~t flame at the source, delayed vapor cloud fire, or vapor cloud explosion. Missile generation may also acc:ompany the rllpture/el<ploslo_n. For the assessment ot an unconfined explosion, RG 1.91 (Reference 3) methodology was used to calculate the minimum safe distance. For the jet flame, cloud fire, and vapor cloud explosion, the ALOHA chemical release modeling computer code (Reference 4) Is used to determine the hazard Impact distances which are compared with the actual distances at IPEC to structures, systems and components (SSCs) related to safety or SSCs Important to safety (SSC ITS), as listed In Reference 2, Table 1, In order to assess the Impact potential. ALOHA is run using the appropriate source tem, (amount of methane released for

...._ _________________________________ Open country ground roughness conditions modeling assumptions were chosen_

EXPLOSION The ALOHA model for el<plosion scenario 1 conservatiVely assumed that the pipe rupture c,ccurred at the far end of the pipe line above the surface, considering the length of pipeline lo be 3 miles.rr§I7)(F)

!(h)(7}(FJ lat a maximum operating pressure of 850 ps1g,'.,l""'h""e""A""L"'Ol'Clfi'l'rA __...

calculaOon for lh1s scenano resulted In a maximum sustained methane release rate of 256.,ooo pounds/min, and estimated total release amount of 354,651 pounds averaged over 9 minutes, conslderlng manual closure of the isolation valves. within 3 minutes, Conset11a.tively assuming the maxim Lim release ovm one minute (256,000 pounds or methane). and determining the TNT equivalent amount with a yield factor of 0.05 (WTNT)

With equation given below. the minimum safe distance (d) to 1 psi overpressure Js calculate1d to be 2351 ft by using RG 1.91 methodology as follows.

WTNT= (Mf

• DHC

• Y)/4500 Where WTNT: TNT equivalent Mass, kg Mf

Mass of vapor, kg 01-IC

Heat of combustion. kj/kg (50030)

Y

= Yield Factor (0.05)

Where d= minimum safe distance (ft) to 1 psi overpressure w= TNT equivalent mass in pounds This calculated minimum safe distance of 2351 ft is smaller than the actual distance of 236:3 ft to the SOGA (Security Owner Control Area) from the pipeline at the far end above surface or 2988 ft to the nearest sefety-retated SSC (nearest safety-related SSC inside SOCA from Is aboulj1bl(7H fn from the edge of the SOCA) and therefore 1 psi overpressure Is not expected at any safety-related SSC inside the SOCA frctm a polentlal rupture and explosion at the far end of pipeline above surface. However, as the calculated,minlmum safe SEH&llll

C:1'41.>I I IV C -

>C\\,UT'tl I 1 l"{C

u-\\ I c:u lr<lr-UrtlVll'\\ I IVN

[Type teJCt] distance of 2351 rt is larger than the ac1ual distar,ces to all SSC ITS, they may experience greater than 1 psi overpressure. Therefore, the SSC ITS would be impacted. Nevertheless, their Impacts are bounded by the severe/beyond design basis accidents considered as part of low probabillzy events such as natural phenomena that in elude seismic, hurricane and tornado events including Loss of Offsi\\e Power and Station Black Out (SBO) considerations with design of redundant systems, engineering safeguards and mitlgatlon measures In Jr lhe plant UFSARs. The frequency of exposure due to failure of these SSC ITS from poten1fal rupture of AIM ,.JY Comment [mlh5]: All oron~ 8oma1 compromised due to rupture of AIM ProJect. ~ P. reject is also briefly presented later in this report lo address whether the margin of safety 1s reduce~or ~ Assuming 5% yield factor for unconfined methane explosion (as given In RG 1,91 ), the metha e, am nt .,,.I1/2 A _n. t('\\'-~~ determined from the maximum 256,000 pounds of methal}$,,eased over one minute (dete ined from the MPµ--~ e,,._; ALOHA run) Is used as an Instantaneous melhan~se, to slmulat~~pa.c...olQIJr;t_dls e tr r and delayed explosion (conservatiVely assuming ~congestion~al structur~lQ,.tba a, a) with the Comment [mlh6J: Assumnd t1*Qh, medium or I ALOHA model. The model determined minimum safe distance to 1 psi overpressure duifodelayed vapor low congeal,~ . ~ cloud explosion is 3054 ft, and Is slightly higher (by 66 ft) than the acti,al distance of 2988 ft to SSC inside the ~ SOCA. However, It should be noted that the determined minimum safe distance assumed Ignition With congestion In the area, and distances to SSC:s from the pipeline are based on the rougti estimates due lo undeveloped area. Moreover, the SSCs are generally designed to Withstand overpressure of 3 psi. !(b)(7)(F) lfh){ 71/F I I as methane rs buoyant and quickly nses aloft. disperses rather rapldly,.....,...,......,.__...., ____.,,.....,.. __..,.. ___,....,,,,_ ___...,,.._..,... ___ ~ Therefore. the ALOHA model was rerun with the same Input except with an assumption of no congestion In the area, The ALOHA model resulted in no vapor cloud explosion of 1 psi overpressure at any distance due to potential Ignition. The potential pipe rupture underground at the enhanced section ot the pipeline, would be expected to result In a slower methane release rate, and thereby have potentially lower impacts than those determined as above. 1 JETFIRE ~ The ALOHA model was run conservatively assuming Iha the rupture of pipe occurred at far end of the pipe line above the surface, considering the lengt of pipeline to be 3 miles, !lb)(l)IF 1 I l{hj(l)\\Fl lat a rnaximum opera1ing pressure of 850 pslg Methane is assumed to be released Fromhe ru tured i e as a flammable gas, burnlng_ The ALOHA model run resulted in a maximum bum rete of (b)(7)(Fl and an estimated total amount burned of 354,651 pounds avera9ed over 9 minutes, sure of the lsolallon valves within 3 minutes. The distances (Table 2) to thermal radiation levels ot!(ti)(?)(F) !5,0 kW/m~. and 2.0 kW/tn2 calculated by ALOHA are.,.!(t...,i)l_7)._ff..,l ____ ___. respectively. The ALOHA model was also run conservatively assuming that the rupture of pipe occurred in the middle of the pipe located underground at the enhanced section fdenlifled close to the SOCA. considerln half he Jen th of the pipeline between isolation valves (1.5 miles) on each side of the rupture location, (h)(7)(F) !(b)(7)(F) !al a maximum operating pressure of 85_,,_ps.. 19-.- e... ~an-e-1-s _ __, assumed lo be released from ruptured pipe segment as a burning flammable gas, The ALOHA model run resulted in a maximum bum rate of!(b)(?)(F) ! cons derlng closure of the 1solatlon valves within 3 minutes. The calculated distances (Table 2) lo the thermal radiation levels ofl(b)(7)(F) 15 0 kW/m2, 2_0 kW/rn~ are 891 ft, 1425 ft and 2223 ft, respecllvely. SEMSIIIVF i5iCI !Rl:r¥ Aik \\iii IUFORMa,leH [Type text] [Type text] The distances determined to the thermal radiation level of (b)1l)(F} which has a, potential to damage structures and egulpment) due to potential pipe rupture at far end of the pipeline or in middle of the pipeline are I (bl( /)(F) I respecUvely. Both of these determined distances are smaller than the actual dlstances of 2363 f\\ and 1580 fl, respectively, lo the SOCA, and therefore, jet fire would not pose any adverse effect on SSCs related lo safety, However, it may impact some of the SSC ITS as the radiation level of !(bl(l)(F) tnay be exceeded for some SSC ITS outside of the SOCA. Nevertheless, the Impacts to SSC ITS are bounded by the severe/beyond design basis ace dents considered as part of seismic and tornado events covering Stat on Black Out (SBO) and Loss of Off site Power considerations with deslgn of redundant systems, engineering safeguards and mitigation measures already addressed ih the plant UFSARs, CLOUD FIRE The ALOHA model was run conservatively assuming that the rupture of i e occurred at far end of the i e line above lhe surface, considering \\he length of pipeline to be 3 miles, (b)( ()(F) (t1)(7)(F) at a maximum operating pressure of 850 psi~g"".,.,..,.e......,-,nTT"...,.m...,.o.,.,.e,......,,ru""n,...r""es..,..u"""'e~ n,...a..,.... maximum sus a ne re ease rate of 256,000 pounds/min. and an estimated total release amount of 354.651 pounds averaged over 9 minutes, considering manual closure of the isolation valves withln 3 minutes. Conservatively assuming the maximum release rate over one minute, 256,000 pounds of methane (determined from the ALOHA run) Is used as an nstanlaneous release over one minute, to simulate the vapor cloud ~ dispersion, transport to determine the distance to reach the methane lower explosive limit (LEL) of44,000 -~

• __r ppm. The ALOHA model determined a distance of 1.8 miles to reach the LEL This estimated distance would if

• I\\:? ~J}

bound the potential distance to LEL from rupture in the middle of pipe In the enhanced area burled / ~ ~ ~ underground. Even though the methane plume travels lo a long distance, It Is buoyant and quickly rises aloft, ~ P--'OC""f°" and, therefore, r bum~ather rapidly In secondstabove the ground without sustaining, ffenou ~ oxygen Is avalla e. Therefore, the impact from clou re on SSCs and equipment ls not cons dered ec,-;;.,;;;;;t[mlh7J: c 1ar11y I'm no1 su"' Whal 1 h II d \\.:_ y011*re lfYlnQ lo say here Even O,o~gh n may C 8 enge

• 1rove1 rar, 1t noos qu,ckly ao O,at any burnlr,g

. l.-.<1 ,_/' _,..,1 Q,/ ' happens far obo\\le lhe gt01Jnd, 11 enough (JJ",- ~*v ' O)O'ga,, 1aava~eblaat 1)1a1 slti!\\Kie? Is O,am twl tlon ur lhe lcfttng (a.g, cloud reachas DETERMINATION OF EXPOSURE RATE FOR FAILURE OF THE AIM PROJECT PIPELINE NEAR IPEC 100011,noSsec(BJCamp1orna~up))? / Based on Pipeline Hazardous Materials Safety Administration (PHMSA) data (www.ph sa,dot.gov), and also pubtrshed 1ntormatlon from "Handbook of Chemical Hazards Analysis Procedures" ference 5), the accident rate of pipes greater tr,an 20 inches diameter is about 5 x 10'.. 1/mile-yr. As.iullllllg.~ miles of AIM Project pipeline near IPEC, the accident rate is determined to be 1.5 x,o~/yr, Assuming~ percent of accidents result In complete break or 100 percent release, and ssumfng only 6 percent of the time that the released gas becomes ignited lead1ng to pote lal explosion, the explosion frequency for the AIM project pipeITne near IPEC is calculated to be about 7 5 >< 1 *1tyr. If this rel se is due to underground pipe, the frequency of explos on will be further reduced by al least a order of magnl ude. In addition, the frequency of large radioactivity release from the reactor due to the freq ency of the abo e pipe nJpture event would be at least few orders of magnitude lower, and thereto would not be ide tified as a design b ls event. Therefore, it is concluded that the pipe failure resulting In a thane release fro proposed AIM Pro ect near IPEC, would not reduce any further the existing safety ma ose a threat to the afe operation of the plant or safe .shutdown. ~ &itlil*ll1i iiiliilURl;nG Riltot;fE8 lflFBRMJ'ifU!IH / CommaM [mlh8]; 1 p~r,I 00,nplel& lalll.ll'* r.iile assl1mpUon based on 'M>&t? Also llie prev1ou* ref ere"""'? Comm~ml [mlh,]i 1l'lef6 aoema to b<l a leap here, What 11 the fieq,.i Ci'/ of ploslcn from 1 pipe rupture leading to large rndloooliv~y 1111&aEfl7 How does lhe u~plosoon 108d lo (0< no\\ lead to) l'ldloeGtr/11)1 re:ea.&7 --- (Type text] SENSI I Iv E SECURi I I RLLA I Etl 11.re~MMl8FJ [Type text] , DDITIONAL CONSIOERA TIONS TO ENHANCE SAFETY MARGIN Although Entergy's hazards analysis is reasonable and shows no reduction to the current safety margin, In view of increasing the margin of safety from potential impacts froJTJ the rupture of the proposed AIM Project pipeline near IPEC, the Staff suggests following recommendations. It should be noted that these are just suggestlo ns for RI staff to consider but not requirements. Consideration may be g ven to locate the proposed pipeline about 200 ft farther away from the SOCA If possible. Thereby, the proposed pipeline would be placed farther away from the safety-related SSCs and SSC ITS and add additional safety margin.

2. Consider increasing the presently planned 100 ft wide clear buffer zone around the-buried pipeline, to a 200 ft wide clear zone, so that buoyant methane would disperse aloft without being trapped/accumulated, thereby reducing the potential for explosion.

}/ CONCLUSION Based on the review of lhe hazards analysts provided as part of Entergy's 10 CFR 50.59 Safety Evaluation related to the AIM Project near IPEC, and staff's independent confirmatory calculation results using conservative assumptions and rationale, the staff concludes that no 1 si ove ressure Is extended to an safety-related SSC Inside the SOCA (b)( T)1F I (h)(7)(r) owever, near wou e a ec e, as e ca cu a minimum sa e s ances o e mpac s are exceeded, but these impacts are bounded by the Impacts from low probability events of extreme natural phenomena that Include seismic, tornado winds, hurricanes which have been assessed and already addressed In UFSAR. Cloud flash fire may occur aloft and bum very rapfdly In few seconds, without affecting any safely related SSCs or equipment, and the existing margin of safety is not expeated to be reduced due to potential rupture of the proposed AIM Project pipeline near IPEC. The staff also finds that 1he applicant's conclusions that the potential rupture of the proposed AIM Project pipeline near IPEC poses no threat to safe operation of the plant or safe shutdown of the plant are reasonable.ind acceptable. The staffs review finds that the hazards analysis supporting the licensee's 10 CFR 50.59 safety evaluation ls appropriate and shows !hat there is not more than a mlnimal increase to the likelihood of occurrence or consequences of damage to a safety-related SSC or SSC ITS, when compared to the current hazards analysis 1n the plant UFSARs. SEIISI II0E - SECORII I R2LAl!U 11411O1\\MSl<ller** () comment [mlhl0]1 Old lhe region ask for such recommendations? I would be careful I about how 10 present 1h11 Since the t,azards analysts show thal Iha proposed locatlon Is acceplabla and also "'within th~ current uraty morgln, th,. reo10n may decide 10 nol dl*cus.o With the licensee. com. ment [mlh11], Consider putll~ I finding s<<itence III lhe doeoment It may be more like wtiat tJie region staff would be saying ln l dooumentllllon [Type text} [Type text) REFERENCE~ Entergy, '10 CFR 50.59 Safety Evaluation and Supporting Analyses Prepared fn Response to the Algonquin Incremental Market Natural Gas Project Indian Point Nuclear Gene*rating Units Nos. 2 & 3', NL-14-106, August 21, 2014. Ml14245A110

2.

Entergy, "Hazards Analysis", Enclosure to NL*14-10&, August 21, 2014. ML14245A111 (Non-public)

3.

US Nuclear Regulatory Commission, Regulatory Guide 1.91, "Evaluations of l:xploslons Postulated to Occur at nearby Facilities and on Transportation Routes Near Nuclear Powllr Plantsi Revision 2. April 2013. 4, US EPA. NOAA.'ALOHA User's Manual", February 2007.

5.

FEMA, US DOT us EPA. "Handbook of Chemical Hazard Analysis Procedures" SEJQSI 1102 - SECORII f RELAI ED INFORJOIAIIOl4 Additional Modeling for proposed AIM Project Pipeline Impact on IPEC Since the validity/uncertainty of valves closure within 3 minutes of pipeline leak/burst considered in the impact evaluation was raised, additional modeling with ALOHA is performed to check the variation of results with and without valves closure. Present modeling considered that the unbroken end of pipe is closed due to valves closure, and the natural gas is allowed to exit untif pipeline is emptied. The impacts are determined based on maximum one minute release as conservative/bounding impact in determining minimum safe distance to 1 psi overpressure, and also potential heat flux due to jet fire at SSC/SOCA. This analysis is remodeled with same conditions by imposing that the unbroken end of pipe is assumed to be connected to infinite source (with no valves closed) tor an hour (limitation of AOHA model). Since the maximum calculated release rate of natural gas by ALOHA model is slightly varied, the calculated results are marginally changed. The distance to 1 psi overpressure changed from 2351ft to 2509ft, which are lower than the distance to SSC of 2988ft. Similarly, the heat flux from jet fire determined at SOCA distance of 1580ft from enhanced pipeline changed from 4.05 kw/sq.m to 4.63 kw/sq.m, and are much lower than the potential threshold heat flux rate of j(hJ(7)(Fl I that would potentially damage the digital equipment. Therefore, it is concluded that the changes in impact results due to closer of valves within 3 minutes or extended period of time, would be minimal, and NRC conclusion of safe operation or safe shutdown of the nuclear units without radiological release, is still valid as NRG acceptance criteria and regulatory requirements are met, whether 3 minute criterion of valve closure is applied or not. However, it should be noted that if valves are not closed for extended period time, potential adverse impacts consisting of property damage, some injuries and possible fatalities may result in due to fire in the close proximity of the pipeline, which is outside the preview of NRC1s regulatory frame work, consideration and jurisdiction from safe operation/shutdown of nearby IPEC nuclear plant perspective. i HWfi&tt iaA&i&i>sa Ofticlal 11 IH Oolt( Additional ModeUng for proposed AIM Project Pipeline Impact on IPEC ~.-. ~--~~ ~ ('(\\ fuu k~ ~ Since the validity/uncertainty of valves closure withi~utes of pipelfne f eak/burst considered ill the impact evaluation was raised, additional modeling with ALOHA is performed to check the variation of results with and without valves closure. Present modeling considered that the unbroken end of pipe is closed due to valves closure, and the natural gas is allowed to exit until pipeline is emptied. The impacts are determined based on maximum one minute release as conservative/bounding impact in determining minimum safe distance to 1 psi overpressure, and also potential heat flux due to jet fire at SSC/SOCA. This analysis is remodeled with same conditions by imposing that the unbroken end of pipe is asi;;umed to be connected to infinite source (with no valves closed) for an hour (limitation of ALOHA model). Since the maximum calculated release rate of natural gas by ALOHA model is slightly varied, the calculated results are marginally changed. The distance to 1 psi overpressun~ changed from 2351 ft to 2509ft, which are lower than the distance to SSC of 2988ft. Similarly, the heat flux from Jet fire determined at SOCA distance of 1580ft from enhanced plpeline changed from 4. w/. 4.63 kw/sq.m, and are much lower than the potential threshold heat flux rate o rb)(7)(F) that would potentially dama9a the digital equipment. Therefore, it is concluded *p1:=--e~c,=,a:::,n""'g':":!es In impact results due to closer of valves within 3 minutes or extended period of time, would be minlmal, and NRC conclusion of safe operation or safe shIutdown of the nuclear units without radiorogical release, is still valid as NRC acceptance criteri,a and regulatory requirements are met, whether 3 minute criterion of valve closure is applied or not. However, it should be noted that if valves are not closed for extended period time, potential adverse impacts consisting of property damage, some injuries and possible fatalities mat result in due to fire in the close proximity of the pipeline, which is outside the preview of NHC's regulatory frame work, consideration and jurisdiction from sc1fe operation/shutdown of nearby IPEC nuclear plant perspective. 8ecblitp8e1131the 0ffielal Wee g,.1., &eea, itt a8eusitive

• 8ffl_tlal tJse Otily Additional Modeling for proposed AIM Proiect Pipeline Impact on IPEC Since the validity/uncertainty of valves closure within 3 minutes of pipeline leak/burst considered In the impact evaluation was raised, additional modeling with ALOHA is performed to check the variation of results with and without valves closure. Present modeling considered that the unbroken end of pipe is closed due to valves closure, and the natural gas is allowed to exit until pipeline is emptied. The impacts are determined based on maximum one minute release as conservative/bounding impact in determining minimum sa1'e distance to 1 psi overpressure, and also potential heat flux due to jet fire at SSC/SOCA This analysis is remodeled with same conditions by imposing that the unbroken end of pipe Is asi;umed to be connected to infinite source (with no valves closed) for an hour (limitation of ALOHA model). Since the maximum calculated release rate of natural gas by ALOHA model is slightly varied, the calculated results are marginally changed. The distance to 1 psi overpressure changed from 2351ft to 2509ft.

which are lower than the distance to SSC of 2988ft. Similarly, the heat flux from jet fire determined at SOCA distance of 1580ft from enhanced pipeline changed from 4.05 kw/sq.m to 4.63 w sq.m, an are much lower than the potential threshold heat ux ra e o /b)(7J(F) that would potentially damage the digital equipment. Therefore, it 1s concluded than anggs in-impact results due to closer of valves within 3 minutes or extended period of time, would be minimal, and NRC conclusion of safe operation or safe sh1utdown of the nuclear units without radiological release, is still valid as NRC acceptance criteria and regulatory requirements are met, whether 3 minute criterion of valve closure is applied or not. However, it should be noted tha_!_if valves are not cJoJi~JLfoLextended g__eriod time, potential adverse impacts consisting of property damage, some inluries and possible fatalities ma~* result in due to fire in the close proximity of the plP.eline, which is outside the prevlew_cf.NB.. C's regulatory frame work, consideration and jurisdiction from safe operation/shutdowIn of nearby IPEC nuclear plant perspective. Sec11ritv Sonsithce Official I Isa Oohs sueot1tv:S@t1S1t1oe orric1at Us& e111v Additional Modeling for proposed AIM Projec~t Pipeline Impact on IPEC Since the validity/uncertainty of valves closure within 3 minutes of pipeline leak/burst considered in the impact evaluation was raised, additional modeling with ALOHA is performed to check the variation of results with and without valves closure. Preser:It modeling considered that the unbroken end of pipe is closed due to valves closure, and the natural gas is allowed to exit until pipeline is emptied. The impacts are determined based on maximum one minute release as conservative/bounding impact in determining minimum safe distance to 1 psi overpressure, and also potential heat flux due to jet fire at SSC/SOCA. This a1nalysis is remodeled with same conditions by imposing that the unbroken end of pipe is assumed to be connected lo infinite source (with no valves closed) for an hour (limitation of ALOHA model). Since the maximum calculated release rate of natural gas by ALOHA model is slightly varied, the calculated results are marginally changed. The distance to 1 psi overpressure changed from 2351ft to 2509ft, which are lower than the distance to SSC of 2988ft. Similarly, the heat flux from jet fire determined at SOGA distance of 1580ft from enhanced pipeline changed from 4.05 kw/sg.m to 4.63 kw/~q.m, and are much lower than the potential threshold heat fl~ (bl(7J(F) I thatJiYould.poteotial!J' damage the digital equipment. Themfore, it is concluded that the changes In Impact results due to closer of vafves wltfiTn-3 minutes o r extended period of time, would be minimal, and NRC conclusion of safe operation or safe shutdown of the nuclear units without radiological release, is still valid as NRC acceptance criteri1a and regulatory requirements are met, whether 3 minute criterlon of valve closure is applied or not. However, it should be noted that if valves are not closed for extended period time, potential adverse impacts consisting of property damage, some Injuries and possible fatalities mai, result in due to fire in the close proximity of the pipeline, which is outside the preview of NIRC's regulatory frame work, consideration and jurisdiction from safe operation/shutdown of nearby IPEC nuclear plant perspective. Sec11rltu Sensitive Official I lee Anh, r1t::J. v*_y, C),~ ~ 5 ~C4. ~ Soc.A ~ C2A11-~~ ~cw ~~fi~ ~~~ +v 'SSc. ~ (,v,.t...:~UL.J ~~ 'cl- ~f~ ~~ ~ +v ~&tlvfrt~ ~ ~ ( ~ 6-u) \\ ~ ~.::, '"""' ""f' ~ ~ ~*=r-.<l h, \\::>e.. ~..,-\\'" 0 ~ 0 ~~ ; (:,\\.. _ \\ iee-u,~., '\\,Ve <;tz_.J-,-~ )-~ ~ ~ ::

• 2./ ':, G ~ b"-

~ ~ ~ ~ s s C. ~ -?,A~ (yvv-rfr-"') ~~ ...... <f ~f'L~ -: 2 Cf -a fj f}- CHAIR THE ASSEMBLY STATE OF NEW YORK ALBANY Real Property T exaUon COMMITTEES Corpora~or.s, Autho1UJes and Commissions Election Law Go11ernmental Operallons SANDRA R.GALEF Assembtywoma n 95111 Of strict Galef: NRC Must Shut Down Approval of Spectra's AIM Pipe1ine Siting at Indian Point Assemblywoman Calls for NRC to Require an Independent, In-Depth Safety Analysis Health (February 25, 2015) In a catastrophic failure scenario, how quickly can a 42-inch high-pressure natural ga~ line in Buchanan New York be shut down from a remote access location in Texa~? The uclear Regulatory Commission (NR ), responsible for the saf ty of all nuclear p wer plants in the .S., believes that failsafe.shutdown could occur in only three minutes. Entergy, the operator of the Indian Point ouclear power plants, conducted a safety assessment of the proposed gas line siting, and came up with the three-minute gas pipeline shutdown estimate, which was then accepted by Lhe uclear Re.gulatory ommission (NRC). When asked by the Assemblywoman for verification of the estimate, the NRC said that Entergy based its estimate on information provided in documents submitted by Spectra Energy to the Federal Regulatory Energy Corn mi ion (

• CRC).

pectra Energy has filed it Algonquin Incremental Market (AJM) prnjecl application with the federnl agency responsible for approving siting of pipelines. The AIM project calls for installing a high pressure and high volume natural gas pipeline that will pass less than Lwo hundred leet from vital structures at Indian Point. New York talc Assemblywoman Galef, who represents Bl1chana11 New York. has raised concern about the three-minute huldown claim. he believes the NRC needs to require a full a,1d complete independent analysis of the safety of the AIM project in relation to Indian roint in which assumptions are properly validated. " [t i*s lrre~ mn 'ble to lake a recommendation from a company like pectra that wanes their business to be here, and not independently validate ii. The safety of the people in the Hudson Valley region should take precedence over lhe interests of two energy production companies. There is no other place in U1is country where a gas pipeline come. as \\]Sf'>-\\:- <I. close to a nuclear power plant as there is here,. o it requires above and beyond oversight and analysis. Galef said,

• .\\,.' ~...A The 'R action violate it. <>W r *, 1 tor obligation to require verifiable safety testing methodology and results

\\J' \\/) ~ for 6~stems related to Jndia11 PoinL Th.e NR.C a cepte Emcrgy's estimate for a safe shutdown of the natural gas ~~~~'°ifcmnc in a catastro,hie ailure and ex lo i, - the information is little more than an unsubstantiated claim of ,J,i:..J r$r\\ Spectra Energy uried in its paperwork submi sion to FERC, To compound the failure of these agencies, FERC then ~ o ~c pied the NRC's explanation. ~~ r U pon a detailed review, pipeline expert Rick KuprewicL. and nuclear expert.Paul Blanch have concl~ l estimated timeframe is inaccurate and efie the law ofthermod)namics should an ex losion occur. In spite ol requests from members of the U.S. House an e 1: \\: an,a, c es er C0tmty legi lators and local elected oftioials, the NR and PER have refu ed to require En1ergy r pectra to have their ~claims veri lied by an independent analysis. ~ --~ '::_We must do a better job analyzin these tcntial threats and shollld not be rushing to any conclusion.~." Galef \\...!I" _ f stated. "The safety of this region is al stake." ~ ¢a.... c,.,)V) ~'"I; tiff# \\ _ ~.,e..:.....,f7 r1.1 tu1-~ f~~ ~c \\. ~~~~ ~~ --~ ~~~~? ~ c'-f~~ ~s ~. ~ Q CJ..Nl__ ~J ? ; µ~dY -- \\) ALBANY OFFICE* Room 841, Legislativo Offic~ Bu1ldl11g, Albany, Naw York 12248, (518) 455-5348, FAX (518) 455-6728 DISTRICT Of.'FUCE: 2 Church Streel, Ossining, New York 10562, (914) 941 -1111, FAX (914) 941-9132 E*MAIL* galefs@assembly.state.ny.us WEBSITE: www.assembly.ateto.ny.us Thermal Radiation at Point Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specified) Chemical Name ; METHANE Building Air Exchanges Per Hour: 0.50 (enclosed office) THREAT AT POINT: Model Run: No Mode Given Thermal Radiation Estimates at the point: Downwind: 580 feet: -..,,.-,,,,...-----. Off Centerline: O feet Max Thermal Radiation: ~l(b_)(_7)_(F_) ___ (b)(?)(F) At Point: Downwind: 1580 feet Off Centerline: 0. fee ALOHA 5.4.1 Text Summary SITE DATA: Location: KINGSTON, NEW YORK Building Ai r Exchanges Per Hour: 0.50 (enclosed office) Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> !IDT (user specified) CHEMICAL DATA: ALOHMO 5 4 1 -t Chemical Name: METHANE TEEL-1: 3000 ppm TEEL-2: 5000 ppm Molecular Weight: 16 04 g/rnol TEEL-3: 25000 ppm LEL: 44000 ppm UEL: 165000 ppm Ambient Boiling Point: -258.8° F Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concen ration: 1,000,000 ppm or 100.0 ATMOSPrfER~C DATA i (~ INPUT OF DATA) wind: j(1/2(l)(F) from E at 3 meters l(b)(7)(F) Ground oughness: open country Cl oud Cover: _ Air '!6:lperature: J(b)(7)(F) I Stabi.11 ty Class: _ No Inversion Hei ht Relative Humidity: (tJ)(l)(F) SOURCE STRENGTH: Flammable gas is burning as Pipe Diameter: 42 inches it escapes from pipe Unbroken end of the pipe is connected Pipe Roughness: smooth Pipe Press: 850 psi2 Max Flame Length : IIS' '"""'";rz-llf_\\ __ Pipe Length: to an i nfini,.._....a.i....,u..i;........., i:iole Area: Pipe Temperature: Burn Duration: ALOHA limj t,gd tbe QJlfr tion to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ~ Burn Rate: lfQ.lf 7)(El Total Arnoun Bu.._rn ....__e __ d.._:.... !(b_)_(J_)(F_) ____ THREAT ZONE: Threat Modeled: Red (IJ)(l)(r) Orange: Yellow: THREAT AT POINT: Thermal radiation from j e t fire

Wi_)~\\(F~W7 (sq m) p 2nd degree burns within 60 sec)

(2.0 kW/(sq m) = pain within 60 secl Thermal Radiation Estimates at the point: Downwind: 1580 feet Off Center inei 0. feet Max Thermal Radiation ; 4 _63 kW/(sg ml Thermal Rad'atioo at. Point ALOHA 5. 4.1 3/4 Time: June 21, 2011 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> EDT (user specified) Chemica 1 Na;ne: METHANE Building Air Exchanges Per Hour: 0.50 (enclosed office) THREAT AT POINT: Model Run: No Model Given Thermal Radiation Estimates a the point: Downwind: 1580 feet. Off Centerline: 0, feet Max Thermal Radia_ion: 4.61 kW/(sq ml (ll)(7)(F) At Point.: Downwind : 1580 feet Off Centerl ne: 0. f eet Th rrnal Radiation 'l'hreat Zone (b)(7)(Fl Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> ED~ (user specified) Chemical Name: METHANE Wind: ~l(I_J)(_7_l(F_) ____ ___.l from Eat 3 meters THREAT ZONE: Threat Modeled: Red (b)(/)(F) Orange: Yellow: ALOll/\\ 60 ser. l

• re:xt Summary SITE DA'l'A:

Location: KINGSTON, NEW YORK Building Air Exchanges Per Hour: 0.50 (enclosed office) Time: June 21, 2-013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specified) CHEMICAL DATA: ALOHA Chemical Name: METHANE TEEL-1: 3000 ppm TEEL-2: 5000 ppm Molecular Weight: 16.04 g/mol TEEL-3: 25000 ppm LEL: 44000 ppm UEL: 165000 ppm Ambient Boiling Pol t: -258.8° F Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHey~C D:A * (MANJJ: INPUT OF DATA) Wind: ~~(7)(F) _ J from E at 3 meters Ground oug ess: o en countr Cloud cover: !(h)(7)(F) Air Temperature: (b)(7)(F) Stability Class: No Inversion He~rtn..-------- Relative Hu.m:.dity: l(b)(l)(F) SOURCE STRENGTH: Direct Source: 15550.0 pounds/min Source Height: 0 Release Duration: 1 minute Release Rae: Total Amount Rel eased:,.b.......,(7...,_F...,_.,...__,,___. Note: This chemical may flas1 oil and/or result in c.wo phase flow Use both dispersion modules to investigate is pocential behavior THREAT ZONE: Threat Modeled: Overpressure (blasc force) from Type of Ignition: ignited by spark or flame Level o Congestion: uncongested vapor cloud explosion Model Run: Gaussian Red LOC was never exceeded Orange: LOC was never exceeded Yellow: LOC was never exceeded THREAT AT POrnT: Overpressure Estimate at the point: Downwind: (b (I Ll.:.1.:.:..1,i::"":"::=::----, Overpressure: (b)(7)(F) (8.0 psi (3. 5 psi (1. 0 psi destruction of buildings) = serious injury likely) = shatters glass) Off Centerline: 0. feet Overpressure at Point Time; June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specified) Chemical Name: METHANE Building Air Exchanges Per-Hour: O. *50 (enclosed off ice) THREAT AT POINT: Model Run: Gaussian Overpressure Escimate at the poin Downwind: lb 7 F ~1.J.11....,..=::"----, Overp~essure: (b)(7)(F) Overpressure: !(ll)(7)(f) Off Centerline : 0. feet At Point : Downwind: ~l(b- )(_7l_(F_l __ ~ Off Centerline : 0 eet ALOHA 5.4.1 ~ Overpressure at Point Time: June 21, 2013 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> EDT (user specified) Chemical Name: ME~HANE Building Air Exchanges Per Hour: 0.50 (enclosed office) THREAT AT POINT: Model Run, Gaussian Overpressure Estimate at the point: Downwind: ~'b"""""~F.-__...__ Overpressure; (b)(7)(F) Overpressure: ~fb_X_~_f_l __ ~ At Point: Downwind: l(b1'J)(F} Off Centerline: 0 feet Off Cencerline: 0. feec ALOHA 5 4,-t ..... l(alth .om: Sent To: Cc: Beaulieu, David Monday, April 27, 2015 12:32 PM Pickett. Douglas; Miller, Chris; McCoppin, Michael; Tammara, Seshagiri; Setzer, Thomas; Carpenter, Robert; Cylkowski, David; Banic. Merrilee; Beasley, Benjamin; Stuchell, Sheldon Trapp, James; Dudek. Michael; Wilson, George; Gray. Mel; Krohn, Paul; Montgomery, Richard; Burritt, Arthur

Subject:

Indian Point Gas line Isolation Time

PRB, Below are the excerpts that I discussed during today's PRB meeting:

1 ) Excerpts from the Indian Point 50.59 evaluation states, "The estimated time to respond to the alarm (less than one minute} and the closure time of the valves (about one minute) was used as the basis for an assumed closure time of three minutes for the analysis performed In the attached report:

2) National Transportation Safety Board 2011 report excerpt that states that "there is no DOT requirement for response time.*

3)* Oak Ridge report from 2012 includes two separate statements about closure time:

"The time between a pipeline break and RCV closure can var, from about 3 minutes for immediate leak or rupture detection to hours If field confinnatlon of a break Is necessary to validate the closure decision:

"Consequently, delays of about 10 minutes will be required before RCV closure can be initiated for a typical line break scenario, If field verification of the break Is not required."

Excerpts from various sections of the lndlan Point 50.59 e.yaluation lnvoMng the 3 minute Isolation time.

"This would result in all the gas between these valves at the time of closure being able to vent or bum. The estimated time to respond to the alarm (less than one minute) and the closure time of the valves (about one minute) was used. as the basis for an assumed closure time of three minutes for the analysis performed in the attached report.*

9The next closest Isolation valve locations are at the Stony Point Compressor Station mile post 0.0 and at MLV 15 at mile post 10.52. Valve operation follows the requirements of the DOT Code and Is tested on a periodic basis to ensure compliance with code requirements."

"This hazards analysis considers the effects of the gas pipeline rupture to Involve the approximately 3 miles of pipeline between Isolation valves and considers the event to be tenninated by manual action within 3 minutes after any pipeline rupture event by closing the closest isolation valves and limiting the event to the gas between these valves." -

• tn modeling releases and their consequences, we assume that the contents of a 3 mile length of gas pipeline are released at a pressure of 850pslg (the MAOP of the 42" pipeline), that valves Isolating this length of pipeline Will be closed within 3 minutes of a major release and that the Interior of th!s pipeline is smooth.*

• After valve closure, full bore release from the pipeline will persist for another 2 to 3 minutes. The release following guillotine rupture will therefore be ~ 5 to 6 minutes duration.*

• eased on an average release rate of 1877 kg/s for a 360-Second period. This rate comprises the release of 376,000 kg In the first minute (from ALOHA), a release of 200,000 kg in the next two minutes (accounting for the pressure drop) and 100,000 kg after valve closure. This last will take an additional 3 minutes after the valves are closed (from ALOHA):

National Transportation Safety Board. 2011. Pacific Gas and Electric Company Natural Gas Transmjssion pjoeune Rupture and Are. San Bruno. California, September 9. 2010. Pipeline -

".Cident Report NTSB/PAR* 11/01. Wa&htngton.

,..,, C. http://www. ntsb.goy/inyestlgationslAccidentReports/Reports/PAR 1101. pdf 1

Pther than for pipelines with alternative maximum allowable operating pressures (MAOP), the regulations do not requi,. a rnponee time to Isolate I ruptlnd gaa lfne, nor do they expllcltly require the uH of ASVs or RCVa. The regulations give the pipeline operator discretion to decide whether ASVs or* RCVs are needed In HCAs as long as they consider the factors fisted under 49 CFR 192.935(c): Automatic shut-off valves (ASV) or Remote control valves (RCV). If an operator determines, based on a risk analysis, that an ASV or RCV would be an efficient means of adding protection to a high consequence area In the event ofa gas release, an operator must install the ASV or RCV. In making that determination, an operator must, at least, consider the following factors-swiftness of leak detection and pipe shutdown capabllltles, the type of gas being transported, operating pressure, the rate of potential release, pipeline profile, the potential for Ignition, and location of nearest response personnel.

Oak BidQe National Laboratory QBNUTM-2012/411, *studies for the Reauirements of Automatic and Remotefv Controlled Shutoff Valves on Hazardous Liquids and Natural Gas Pipelines with Respect to Public and Environmental Sefety.* December 2012.

http;l1www.phmsa.dot.gov/pv obj cache/pv obj id 2C1A725B08C5F72f305689E943053A96232AB200/fifename/Fin a!%2QYalye Study.pdf Conclusions from the "Cost Benefit Study of Remote Controlled Main Line Valves" (Sparks, 1998) follow.

1. Virtually ell injuries caused by pipeline breaks occur at, or very near, the time of the Initial rupture. Of 81 injury incidents reviewed (1970 to 1997 NTSB Incident Reports), 75 reported injuries at the initial rupture. Of the other six Incidents, four occurred within 3 minutes of the rupture. It seems clear, therefore, that early valve closure time will have little or no effect on Injuries sustained, and no effect on rupture severity. Valve closure wilt be *after the fact* as far as most Injuries and damage are conceme.d. There Is no evidence that prolonged b'lowdown of a ruptured line causes injuries.

2. Further, a Une break does not immedi,tety evacuate the pipellne. Because of llne pack (gas compressibility) some 5 to 10 minutes are nonnally required for low pressure alenns to be generated at Gas Control and/or nearby compressor stations. Delays depend upon break size and location, !lne size. operating pressure, and other <>perating and conflguratlonal variables: Additional time Is then.required (a) to detennine the cause of low line pressure (e.g., loss of compression, load transients, faulty instrumentation, line break, or other causes) and (b) to determine break location. This will likely consume an additional 5 minutes. Conlequently, delays of about 10 minutes wlH be n,qulred b9fcn RCV c:lolllrt ean be lnltlatH f<< a typleal line bntlk 1c.narto, If field verification of the break 11 not requlntd. Early valve closure can, however, have a significant effect In reducing the volume of gas lost after a line break. Simulations show savings of about 50% for valve closure at 10 minutes versus closure at 40 minutes In a typical 30-lnch/900-psl rupture scenario.

A different section* of the Oak Ridge Report states:

The decision to close a RCV involves evaluating the sensor data received at the remote location and determining whether a problem does, or does not, exist. The evaluation process includes consideration of real-time pressure and flow data and communications with the public, emergency responders, or company field personnel. If the operator determines that block valve closure is necessary, the operator Initiates the closure procedure by sending a signal to the valve site via the communications link. The time betwHn

• pipeline break and RCV closure can vary from about 3 minutN for Immediate leak or rupture detection to hours If field confirmation of a break-le neceeHry to valldate the ~oawe decielon.

DAVID BEAULIEU PROJECT MANAGER NRR/DPR/PGCB (bawl-yer) 301-41S-3243 I 012D14 I David.Beaulleu@nrc.gov U.S. Nuclear Regulatory Commission 2

Tammara, Seshagiri From:

Sent:

To:

Cc:

Subject:

Attachments:

M1ke/Ooug/Glen*

Tammara, Seshagiri Friday, December 04, 2015 9:27 AM Mccoppin, Michael; Pickett, Douglas; Dentel, Glenn Hollcraft, Zachary FW: RE: existing pipeline hazard evaluation write-up for IPEC allegation Indian Pt-Rao*s Allegation_analysis_writeup (w corrections 12-3-15) (00000002).docx, IPEC_exisiting_pipelines_irnpact_writeup_redac,pdf l(b)(B)

I Mike attached and transmitted the a bove file yesterday. In case there is a FOIA request. I have identified in yellow/red the potential results that may be redacted, and attached that scanned file ( pdf) for your convenience and easy referral Thanks.

Rao From: Mccoppin, Michael Sent: Thursday, December 03, 2015 3:54 PM To: Tammara, Seshagiri <Seshagiri.Tammara@nrc.gov>; Dentel, Glenn <Glenn.Dentel@nrc.gov>; Pickett. Douglas

<Douglas.Pickett@nrc.gov>

Cc: Hollcri:lft, Zachary <Zachary.Hollcraft@nrc.gov>

Subject:

RE: RE: existing pipeline hazard evaluation write-up for IPEC allegation

Folks, Some minor edits as discussed between Glenn, Rao, and I today. Please feel free to make any editorial edits as you see fit Regards.

Mil,;L' iVh:Coppin, MBA. PMP Branch Chief. Radiation Protection &

Accident Consequences (RPAC)

Office of New Reactors United States ~Juclear Regulatory Commission

1 Mail Stop T7-F03 Office T7-F18 W Ph Cell FAX A

Ema11* michael mccoppin@nrc gov

From:

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Subject:

Attachments:

Importance:

Mccoppin, Michael Tue, 1 Dec 2015 14:55:19 -0500 Tammara, Rao;Dentel, Glenn;Pickett, Douglas Hollcraft, Zachary RE: existing pipeline hazard evaluation write-up for IPEC allegation Indian Pt-Rao's Allegation_analysis_writeup (w corrections 12-1-15).doc High Rao... my edits are included.

Thanks, Mike McCoppin, MBA, PMP Branch Chief, Radiation Protection &

Accident Consequences (RPAC)

.DSEAl@@e@

D IVISION OF" &ITC: SAf' TY AND l!NVIRONM NTAL ANALY I Office of New Reactors United States Nuclear Regulatory Commission EiD Mail Stop: T7-F03 Office:

T7-F18 Ir Ph:

3014156533 Cell: !(b)(6)

I

..Ji FAX: 301.415.5399

-'el Email:

michael.mccoppin@nrc.gov NOTICE: This electronic message Is lntende ntity to whom it is addresse infor under app communl

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-:llMi..,'1_~

• er of this me responslbl have rec e original message and any cop

INTRODUCTION Sli~Jiil*l>Jlii iliiCI IRITY Ail ATED IMFORM4IION Confirmatory Analysis of Allegation Concern Evaluation Of Existing Pipelines Rupture Impact At Indian Point Energy Center (IPEC)

The licensee, Entergy, provided a response to NRC Request for Information (Rl-2015-A-0074).

As a part of the staffs review and evaluation of the response and associated attachment and enclosure, the NRC staff performed independent confirmatory calculations to ascertain the reasonability of approach, assumptions and methodology that Entergy used in their evaluation of consequences for the consideration of resolving the concerns raised in this RI. The staffs confirmatory calculations include the determination of the distance to 1 psi overpressure due to potential release of natural gas and explosion at the source of release, due to vapor cloud explosion, and distance to potential heat flux of 12.6 kw/m2 due to release of gas as a jet fire.

SUMMARY

OF EVALUATION Entergy evaluated the potential hazards to safety-related structures, systems, and components (SSCs) and also SSCs important to safety (SSC ITS) using the BREEZE computer model with reasonable approach and assumptions. The staff performed independent confirmatory calculations with conservative assumptions and rationale using RG 1.91 methodology for source explosion and also used the ALOHA computer model for vapor plume explosion. The staff used the ALOHA model to perform the confirmatory calculations to determine:

1) Distance to 1 psi overpressure due to release and potential at source (at pipe rupture),

2) Distance to 1 psi overpressure due to delayed vapor cloud explosion,

3) Distance to heat flux of 12.6 kw/m2 from natural gas release as jet fire.

The staffs independent confirmatory calculation results are based on highly conservative assumption and rationale by modeling an instantaneous maximum one minute gas release rate for the potential explosion at the source. The rupture of the pipeline is assumed to be located at the closest SSC. Based on this, the staff concludes that 1 psi overpressure is extended to a distance ofj(b)f7;(F; ~ which could potentially impact the safety-related SSCs and also the SSCs important to sa e y. Since the pipeline is buried underground, a more reasonable average release rate, as calculated using ALOHA to determine total amount of gas released over the

µ.i.u~'ll(riod to empty the pipeline, results in a recalculated distance to 1 psi overpressure of (b)(7)(F)

In general, the review criterion of 1 psi overpressure provides a margin to failure of safety related SSCs. The safety-related SSCs are designed to withstand overpressure of 3 psi or more without loss of their safety functions. In order to estimate the distance to potential 3 psi overpressure, using the same average release rate, the distance to 3 psi overpressure is calculated to be j(b)(7)(Fl I The staffs analysis of the distance to overpressure of 1 psi due to a delayed vapor cloud

!l!!N!l"l'IVI!!

9ECUfUPV "ELATEB U~FORMATIOH

9Ef49FFl't'E SE0URIT>f RELAiEB IUFORMA*IOH explosion assumed congestion in the area of release. The results extend the 1 psi overpressure to impact some safety-related SSCs and SSCs important to safety. However, the overpressure did not exceed 3 psi at any distance (to any SSCs). A sensitivity analysis, which, more realistically, assumed 110 congestion in the area, resulted in no 1 psi overpressure at any distance due to vapor cloud explosion.

Using the ALOHA model, the staff calculated that the thermal radiation level of 12.6 kW/m2 would extend to a distance of (b)mw:

Based on the results of the confirmatory analysis, the staff concludes that the safety related SSCs, as well as SSCs important to safety, would potentially be exposed to 1 psi overpressure, and a few SSCs important to safety may be exposed to heat flux of 12.6 kw/m2, which is comparable to the licensee's conclusions.

TECHNICAL EVALUATION The staff performed an independent confirmatory analysis based on the rupture of the existing 30-inch natural gas pipeline, which consists of about 6 miles of pipeline between isolation valves. The analysis assumed that a rupture of the natural gas pipeline may result in an unconfined explosion or jet flame at the source or in a dellayed vapor cloud explosion downwind.

For the assessment of an unconfined explosion, the staff used RG 1.91 methodology to calculate the minimum safe distance due to the source explosion. For the jet flame and delayed vapor cloud explosion, the staff used the ALOHA chemical release modeling computer code to determine the hazard impact distances to compare with the actual distances to SSCs related to safety or SSC ITS, in order to assess the impact potential. The ALOHA code is used to calculate the amount of methane released for the scenario considered, using conservative meteorological conditions consisting of an assumed wind speed of 1 m/s, F stability, and 25 deg. C ambient temperature, cloud cover of 0.5 and relative humidity of 50%. Open country ground roughness conditions modeling assumptions were chosen as being appropriate for the location.

Explosion The ALOHA code model for an explosion scenario conservatively estimated the gas release from a pipe rupture at the closest location to an SSC by considering the length of pipeline to be 6 miles, with the rupture creating a hole equivalent to the diameter of the pipe (30 inches diameter) at a maximum operating pressure of 1tb)(7)(F) I The calculation results give a maximum sustained methane release rate and estimated total release amount over time (to calculate average release rate), based on the closure of the isolation valves following the rupture, assuming that the entire volume of gas in the pipeline section between the closed valves is being released.

Conservatively assuming the maximum one minute release rate, and determining the TNT equivalent amount with a yield factor of 0.05 (WTNT) (equation given below), the minimum safe distance (d) to 1 psi overpressure is calculated by using RG 1.91 methodology as follows:

WTNT= (Mf

• DHC

• Y)/4500 where WTNT= TNT equivalent Mass, kg Mf = Mass of vapor, kg DHC = Heat of combustion, kj/kg (50030)

Y = Yield Factor (0.05) and d= 45 * (w)113 where d= minimum safe distance (ft.) to 1 psi overpressure w= TNT equivalent mass in pounds The staff calculated that the safety ~

SSCs, as well as the SSCs important to safety, located beyond a minimum safe distance of~

will not be exposed to an overpressure of 1 psi. As the pipeline is buried underground, the use of maximum instantaneous one minute gas release rate may be overly conservative. Therefore, an average rate of gas release based on total amount of gas released over the time period to empty the pipeline, as calculated using ALOHA is assumed as a reasonable value. Usin this average gas release rate, the distance to 1 psi overpressure was re-calculated to be (b)rHF)

Generally the safety-related SSCs are designed to withstand overpressure of 3 psi or more. In order to estimate the distance to potential 3 psi overpressure, usin the same average release rate, the distance to 3 psi overpressure is calculated to be tb~7HF, The staff's analysis of the distance to not exceed an overpressure of 1 psi due to delayed vapor cloud explosion assumed congestion in the area of release, which would represent dense forest or buildings which enhance gas accumulation due to potential confinement. The results extend the 1 psi overpressure distance to impact some safety-related SSCs and SSCs important to safety. However, the overpressure did not exceed 3 psi at any distance (for any SSCs). These results are comparable to that of the licensee's analysis results. A sensitivity analysis, which more realistically assumed no congestion in the area, resulted in no 1 psi overpressure at any distance due to vapor cloud explosion.

Jet Fire The ALOHA code for jet fire scenarios was run conservatively for the pipe rupture at a location closest to an SSC by considering the length of the pipeline between isolation valves to be 6 miles, with rupture creating a hole equivalent to the diameter of the pipe (30 inches diameter) at a maximum operating pressure of l(b)(7)(Fl I Methane is assumed to be released from the ruptured pipe as a flammable gas and is assumed to be burning. The ALOHA calculation resulted in a maximum burn rate as well as an estimated total amount burned over time, based SENSIJIYE - §fCllBIIY REI AIFD INEOPMAIION

iliiililll><liii

~liiiCI IRllY Aliiib0lliii0 l IFOADUllOI on closure of the isolation valves following the rupture. Based on the assumption that the entire volume of gas in the pipeline section between the closed valves is being released, the distances to thermal radiation levels of 31.5 kW/m2, 12.6 kW/m2, and 5.0 kW/m2 calculated by ALOHA are l(bJl711r1 jrespectivety. A few safety related SSCs and SSCs important to safety may be impacted. These results are consistent with the licensee's analysis results.

CONCLUSION Based on the results of the staffs independent confirmatory analysis, the staff concludes that the safety-related SSCs as well as SSCs important to safety would potentially be exposed to 1 psi overpressure, and a few SSCs important to safety may be exposed to heat flux of 12.6 kw/m2, which is comparable to the licensee's conclusion. Although the licensee's pipeline hazard impact evaluation used different models, assumptions, and methodology than the staff used in its independent confirmatory analyses, the staff's results and conclusions are consistent with the licensee's results and conclusions. Therefore, the staff considers the licensee's hazard impact evaluation to be reasonable and acceptable.

8EP481"fl't'E 6E0URIT¥ RELATE9 l~ffORMA:J"IOH

Proposed Spectra Energy 42-inch Diameter Natural Gas Pipeline Indian IPoinl What is the project. and what federal agency has responsibility to approve or deny?

What is the NRC role? Whal is IPEC role in reviewing this project.

What steps has the NRC taken (50.59 inspection. 2.206. allegations)

Pipeline Location The pipeline is closest to Unit 3. The majority o: the safety equipment is localed inside the SeyooG-11:l& protected area fence. Outside this fence is the security owner-controlled area (SOCA) fence. The closest distance from the SOCA fence to the pipeline will be 1580 feet.

.Safety-related [SSCs are hundreds of feet further away. Because of the proximity of the pipeline to the nuclear plants. Spectra will-plans include "enhancein9."i(b\\U)ff) I of piping closest to the SOCA fence. Enhanced piping will be thicker, buried deeper, and will be located beneath concrete slabs for additional prysical protection.

What are the Concerns Regarding Safety of the Indian Point Nuclear Plants?

There are two issues that could adversely affect safety equipment needed lo shut down the plants and keep them in a safe condition: 1) Overpressure pulses resulting from alill§A explosion, and 2) heat flux from a jet-pressurized gas fire. The staff's analysis confirmed that the threshold values /below which there would not be damage to important safety equipment) of 1.0 ps~ from overpressure eventsr-WR&f-8 glass will be.brek&A,and 12.6 ~w/m2 heat flux from a jet-lli!§..fire,,.,here plasliG will FAell, will not be exceeded. Safety-felateG structures are robust and would also not be adversely affected.

Staffs Use of the ALOHA (Areal Locations of Hazardous Atmospheres) Comput-er Code IPEC performed an evaluation that showed that there was no significant adverse effect on safety related equipment from the pipeline. including from a break in the pipeline. The NRC reviewed that evaluation and associated calculations and agreed with the licensee*s evaluation. The NRO lat61" used a oonservative-model to ensure that the IPEC evaluation was appropriate. The NRC used the ALOHA Computer Code to make this determination.

The code was-DQ'eveloped by EPA and NOAA,_1 ALOHA is an industry accepted code that models chemical releases, including gas pipelines, and dispersions. Versions of ALOHA have been in existence since the early 1980s. The NRC has used ALOHA in reviews ot xx.

yy and ZZ for AA years. NRC staff have significant use in this modeling application for reviewing the effects of gas pipelines and tanks on nuclear plant structures. systems and components. /or use Mccoppin words)

ALOHA is an appropriate tool for this application. The NRC staff compared pipeline release rates calculated manually by hand with those calculated by ALOHA, and ALOHA predicted maximum and average release rates that are greater than the release rates calculated by hand and, therefore, are considered conservative for this application.

The staff assumed a worst case double-ended I\\Jpture of the 42-inch diameter pipeline.

When analyzing a double-ended rupture, flow will be released from both ends of the broken pipe. The majority flow will be from the upstream side which is the direction of flow.

However, there will also be flow from the downstream side, i.e., reverse flow.

Tne ALOl-lA User's MaAual stales: "ALOH.l\\ oanRol FRodo/ gas rolease ffem a pipo !Rat /:las t>rokon in !Re pq/f/41.e anf/ is leaking frern t>et/:1 t>roken enf/s." This siFAJ:JIY FAeaAs t-=iatSince ALOHA only models the upstream mass release, i.e., the direction of flow, and it does not Commented [MC1J: This "one pager" may have lo be a 2 or more pager to be suitable for EPW and do what Iha 3 different Commisioner s have asked.

Commented [TS2): I think it is to be stated that NRC's primary responsibility Is lo ensure that the proposed pipeline would not adversely impact the safe operation or shutdown of IPEC unils. Also slate NRC regulatory requirements. guidance, and acceplance criteria are considered in the independent confirmatory plant safety evaluation analysis. It is also better to state for clarity, that other potential adverse impacts thal may polenllally effect the general public, personnel, property and environment close proximity of the pipeline are not part of NRC's jurisdiclion, and therefore are out of scope of NRC's review and evaluation.

I Commented [MC3J: Spell oul Commented [MC4): Spell oul Commented [MCSJ: Spell oul Commented [TSSJ: performed an independent confirmatory analysis Commented [TS7J: newly proposed EMy Site Permit (ESP) and Combined License (COL) applications for nuclear uni ls at leasl for the past 10 years. It is widely used model for performing impact evaluations.

model reverse flow from the downstream side. the NRC conservatively modeled the gas flow used In the code by assuming the maximum flow Initially experienced at the beginning of the pipe break. and doubling that flow: and determining the effects if that flow were to continue for at least an hour. In order to conservatively model reverse flow from the downstream side of the pipeline break, the staff simply doubled the flow rate calculated by ALOHA from the upstream side. This is clearly bounding and results in a mass release that is greater than what would occur following an actual pipe rupture.Becasue the NRC confirmatory analysis conservatively assumed the maximum initial flow of gas coming from both sides of a potential break. no further transient analyses of the gas flow upstream or downstream of the postulated break in the piping was deemed necessary.

fi. petitioner has been adamant is staling tllaUhe ALOHA limitation noted above specifically pAAlieil6-it6-IJS& fn analyzing pffJ8HR~Toe-sla~~t-itfGReFS claim. Rather, the staff's modeling is bounding and conservatiue. The calculate!J pressure al-the SOGA fence did not oxseed the thresholEi 1,al.ie of 1.Q psi.

,A,LOHA also calculates the heat flux from a jet fire. The heat flux al the SOGA fo1ce die net

~seeEl-tR&-t~re&hola \\'alue of 12.e kwlm2" Rwuest-f-Of.a...+fansi6flt-Ri6k-Analysi6

_* _ A-f)afilioneH1a~too~esleG-lhat a transient risk analy,sis-l:Je-irn;h,1dea as part of aA iRG6f)6AG&nl-assessmeni-of..t~e-pipeliRe,....+h&-Gtaff.!6..analyois-assumed-lhat-lhe-maximum release rate was sustained ans die not decline in the manner that a transient analysis would j)t'8G~~y&is-bo1,md&-a more Eletailea-analyses, sush as. 3-tfaf.\\Sient analysis.

What has the t-JRC determined, and communicated to FERC? Need some words like, The NRC has determined that the analysis conducted by IPEC appropriately analyzed that there would be no adverse affect of the pipeline on safety related equipment. The NRC provided that assessment to FERC. The NRC heard a petition to change that decision. After significant interaction with the petitioner. and evaluation of the facts. the NRC determined that there was no change in the decision regarding the IPEC evaluation. FERC authorized the construction of the pipeline to begin on xxxx. YYYYY.

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From:

Mccoppin Michael To:

Tammara Seshagirj

Subject:

IP Notes Date:

Wednesday, June 01, 2016 10:07:22 AM Spectra Energy applied to FERG for certificate to build 42-inch natural gas pipe-line. FERG/DOT certify and regulate Natural Gas Pipelines. NRG licenses, regulates, and inspects nuclear reactors and radioactive materials.

Entergy was required by NRG to conduct a 1 O CFR 50.59 analysis on pipeline impact on IP NRG was not required to conduct analysis NRG chose to conduct an inspection and independent analysis NRG concluded that pipeline will not impact operation and safe shutdown of IP for pressure wave and thermal flux.

NRG used conservative modeling and assumptions in its models used for analysis.

NRG independent analysis resulted in< 1 psi pressure wave (break glass) and<

12.5 kw/m2 (melt plastic) at the SOGA fence.

NRC models are bounded by actual 42" pipeline explosions in which the worst case heat flux (scorched earth) was half the distance to the SOCA fence. Hundreds of feet from any safety related equipment.

Mike McCoppin, MBA, PMP Chief, Geoscience & Geotechnical Engineering Branch 1 (RGS1 )

DIVISION or 61Tt Al71ITY AND ENVIRONMENTAi. ANAL.Y IB Office of New Reactors United States Nuclear Regulatory Commission 6"l Mail Stop: T7-F03 Office:

T7-F18 if Ph:

301.415.6533

~ FAX: 301.415.5399

..leJ Email: michael.mccoppin@nrc.gov only individual or entity to whom it is addressed. It may co Information t onfidentlal and under appl this

&li~J&l:r:PJE

&EGURl::P/ RELAfEB IHFORMilcfler~

BES'I' AV Confirmatory Analysis of Allegation Concern Evaluation Of INTRODUCTION Existing Pipelines Rupture Impact At Indian Point Energy Center (IPEC)

The licensee, Entergy, provided a response to NRC Request for l11formation (Rl-2015~A-007 ).

As a part of the staff's review and evaluation of the response and associated attachment and enclosure, the NRC staff performed independent confirmatory calculations to ascertain the reasonability of approach, assumptions and methodology that Entergy used in their evaluatio of consequences for the consideration of resolving the concerns raised in this RI. The staff's confirmatory calculations include the determination of the distance to 1 psi overpressure due o potential release of natural gas and explosion at the source of release, due to vapor cloud explosion, and distance to potential heat flux of 12.6 kw/m2 due to release of gas as a jet fire.

SUMMARY

OF EVALUATION Entergy evaluated the potential hazards to safety-related structures, systems, and compone s (SSCs) and also SSCs important to safety (SSC ITS) using the BREEZE computer model wit reasonable approach and assumptions. The staff performed independent confirmatory calculations with conservative assumptions and rationale using RG 1.91 methodology for sou ce explosion and also used the ALOHA computer model for vapor plume explosion. The staff u ed the ALOHA model to perform the confirmatory calculations to determine:

1) Distance to 1 psi overpressure due to release and potential at source (at pipe rupture),

2) Distance to 1 psi overpressure due to delayed vapor cloud explosion,

3) Distance to heat flux of 12.6 kw/m2 from natural gas release as jet fire.

The staff's independent confirmatory calculation results are based on highly conservative assumption and rationale by modeling the gas release rate for the potential explosion at the source. The rupture of the pipeline is assumed to be located at the closest SSC. Since the pipeline is buried underground, an average release rate, as calculated using ALOHA to determine total amount of gas released over the time period to empty the pipeline, results in calculated distance to 1 psi overpressure of (b)(?)(F)

In general, the review criterion of 1 psi overpressure provides a margin to failure of sa e y related SSCs. The safety-related SSCs a e designed to withstand overpressure of 3 psi or more without loss of their safety functions. In order to estimate the distance to potential 3 psi overpressure, usin the same average releas rate, the distance to 3 psi overpressure is calculated to be (b)1'7)(F)

The staff's analysis of the distance to overpressure of 1 psi due to a delayed vapor cloud explosion assumed congestion in the area of release. The results extend the 1 psi overpressure to impact some safety-related SSCs and SSCs important to safety. However, t e overpressure did not exceed 3 psi at any distance (to any SSCs). A sensitivity analysis, whic,

$fN$1JIYf $EGIIBIIY BEi AJEQ INEORMAIION BLECOJIY

91!!1491:Pl't'E

• SEeURl"fV RELA"fE8 IHFORMilt=FIOU BES'l 1 AVAltABU~ COPY m re realistically, assumed no congestion in the area, resulted in no 1 psi overpressure at any di lance due to vapor cloud explosion.

U ing the ALOHA model, the staff calculated that the thermal radiation level of 12.6 kW/m2 w uld extend to a distance ot l(b)(7)(F) I B sed on the results of the confirmatory analysis, the staff concludes that the safety related S Cs, as well as SSCs important to safety, would potentially be exposed to 1 psi overpressure, an a few SSCs important to safety may be exposed to heat flux of 12.6 kw/m2, which is co parable to the licensee's conclusions.

T staff performed an independent confirmatory analysis based on the rupture of the existing 30 inch natural gas pipeline, which consists of about 6 miles of pipeline between isolation va ves. The analysis assumed that a rupture of the natural gas pipeline may result in an un onfined explosion or jet flame at the source or in a delayed vapor cloud explosion downwind.

F the assessment of an un9onfined explosion, the staff used RG 1.91 methodology to ca culate the minimum safe distance due to the source explosion. For the jet flame and de ayed vapor cloud explosion, the staff used the ALOHA chemical release modeling computer co e to determine the hazard impact distances to compare with the actual distances to SSCs rel ted to safety or SSC ITS, m order to assess the impact potential. The ALOHA code is used to alculate the amount of methane released for the scenario considered, using conservative m teorological conditions consisting of an assumed wind speed of 1 m/s in the direction of the S C, F stability, 25 deg. C ambient temperature, cloud cover of 0.5 and relative humidity of 501/o. Open country ground roughness conditions modeling assumptions were chosen as being ap ropriate for the location.

T ALOHA code model for an explosion scenario conservatively estimated the gas release a pipe rupture at the closest location to an SSC by considering the length of pipeline to be 6 miles, with the rupture creating a hole equivalent to the diameter of the pipe (30 inches di meter) at a maximum operating pressure of 674 psia. The calculation results give an es imated total methane release amount over time (to calculate the average release rate) based on th closure of the isolation valves following the rupture, assuming that the entire volume of gas in he pipeline section between the closed valves is being released.

As urning the average release rate, and determining the TNT equivalent amount with a yield fa tor of O 05 {WTNT) (equation given below), the minimum safe distance (d) to 1 psi ov rpressure7s calculated by using RG 1.91 methodology as follows:

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9Ef~9FFPtE SESl:JRlfY REb.A.lEiD l~lfQAHA::t:10~1 WTNT= (Mf

• DHC

• Y)/4500 where WTNT= TNT equivalent Mass, kg Mf = Mass of vapor, kg DHC = Heat of combustion, kj/kg (50030)

Y = Yield Factor (0 05) and d= 45 * (w) 113 where d= minimum safe distance (ft.) to 1 psi overpressure w= TNT equivalent mass in pounds HES1 11lVAI 1lHtE COPY As the pipeline is buried underground, an average rate of gas release based on total amount gas released over the time period to empty the pipeline, as calculated using ALOHA is assumed. Using this averag,e gas release rate, the distance to 1 psi overpressure was calculated to be (b)(7)(F)

Generally the safety-related SSCs are designed to withstand overpressure of psi or more. In order to estimate the distance to potential 3 psi overpressur using the same average release rate, the distance to 3 psi overpressure is calculated to be l(b)(7)(F)

The staff's analysis of the distance to not exceed an overpressure of 1 psi due to delayed vap r cloud explosion assumed congestion in the area of release, which would represent dense for t or buildings which enhance gas accumulation due to potential confinement. The results exten the 1 psi overpressure distance to impact some safety-related SSCs and SSCs important to safety. However, the overpressure did not exceed 3 psi at any distance (for any SSCs). Thes results are comparable to that of the licensee's analysis results. A sensitivity analysis, which more realistically assumed no congestion in the area, resulted in no 1 psi overpressure at any distance due to vapor cloud explosion.

Jet Fire The ALOHA code for jet fire scenarios was run conservatively for the pipe rupture at a location closest to an SSC by considering the length of the pipeline between isolation valves to be 6 miles, with rupture creating a hole equivalent to the diameter of the pipe (30 inches diameter) t a maximum operating pressure of 674 psia. Methane is assumed to be released from the ruptured pipe as a flammable gas and is assumed to be burning. The ALOHA calculation resulted in a maximum burn rate as well as an estimated total amount burned over time, base on closure of the isolation valves following the rupture. Based on the assumption that the enti volume of gas in the pipeline section between the closed valves is being released, the distanc s to thermal radiation levels of 31.5 kW/m2, 12.6 kW/m2, and 5.0 kW/m2 calculated by ALOHA re l/6}(7)(F) r espectively. A few safety related SSCs and SSCs important to safe y m ay be impacted. I hese res,ults are consistent with the licensee's analysis results.

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Sal\\lil::r:U'lii SESijRl:!fY ffELA:T!D ll~fl01'IOIA I ION B&~'I' A\\1AIIARLE COPY B sed on the results of the staff's independent confirmatory analysis, the staff concludes that t

safety-related SSCs as well as SSCs important to safety would potentially be exposed to 1 p i overpressure, and a few SSCs important to safety may be exposed to heat flux of 1.6 kw/m2, which is comparable to the licensee's conclusion. Although the licensee's pipeline h zard impact evaluation used different models, assumptions, and methodology than the staff u ed in its independent confirmatory analyses, the staff's results and conclusions are consistent w th the licensee's results ana conclusions. Therefore, the staff considers the licensee's hazard i pact evaluation to be reasonable and acceptable.

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